G.R. No. 145527 - Gan vs. Reyes

Atty. Lolito G. Aparicio, acting as both counsel and litigant, filed a Motion for Inhibition addressed to the Honorable Judge Ermelindo C. Andal.
The motion alleged that Judge Andal should recuse himself from handling all pending cases involving the petitioner, both criminal and civil, due to an alleged state of hostility.

Filed on September 26, 1988, the motion contained a confidential letter from the Supreme Court’s Deputy Court Administrator and other appended documents.
The motion sought the judge’s self-inhibition based on claims of prior adverse actions—specifically, petitions for certiorari and administrative cases previously filed against Judge Andal.
Despite not stating explicit grounds on its face, it was contended that the judge was aware of the underlying reasons, which purportedly justified the inhibition.

On October 11 and 12, 1988, Judge Andal issued orders denying the petitioner’s Motion for Inhibition in a series of criminal cases (Nos. 1371, 1439, 1475, 1480, and 1476) as well as in civil cases (Nos. 742 and 755).
The orders were reportedly consistent across cases, reflecting the judge’s decision not to be disqualified despite the pending special civil action for certiorari, prohibition, and mandamus.
The denial was supported by the prosecuting fiscal and the counsel for the other parties, reinforcing the notion that no valid grounds were presented.

The petitioner argued that the judge’s refusal to inhibit himself amounted to grave abuse of discretion and a lack of jurisdiction, thereby violating his constitutional rights to due process, equal protection, access to the courts, and speedy trial.
He asserted that continued involvement of Judge Andal in these cases resulted in mental anguish and incurred expenses for himself and his family, warranting compensation under Article 32 of the Civil Code.
The petitioner further emphasized a purported personal enmity stemming from earlier legal actions (certiorari and administrative cases) filed against Judge Andal even before the inhibition motion was submitted.

Judge Andal maintained that the motion for inhibition failed to cite any valid or legally cognizable grounds.
He asserted that he was not even aware of the related administrative case (A.M. No. RTJ-88-245) until a later directive from the Supreme Court.
The judge dismissed the petitioner’s claims of personal vendetta, stating that as a practitioner he too had filed certiorari cases, and emphasized that his actions were solely anchored in fulfilling his judicial duties.
He argued that his denial was based on sound legal reasoning and proper judicial discretion, with no evidence of arbitrariness, bias, or prejudice.

Whether Judge Andal committed grave abuse of discretion amounting to lack of jurisdiction by denying the petitioner’s Motion for Inhibition.
Whether the motion, deficient in expressly stating valid grounds on its face, could serve as a basis for disqualifying a judge from presiding over cases.

Whether Judge Andal’s continued adjudication of the cases, despite the alleged hostility and pending actions against him, compromised the petitioner's constitutional rights (due process, equal protection, access to courts, and speedy trial).
Whether the judge could be held civilly liable for damages under Article 32 of the Civil Code for any supposed impairment of these rights.

Whether the filing of prior petitions for certiorari and administrative cases against Judge Andal could legally justify a claim of bias or hostility on his part.
Whether the mere pendency of such cases alongside the administrative case affects the judge’s impartiality and mandates his inhibition.