Case Digest (G.R. No. L-45121)
Facts:
- Rosario P. Arceo is the petitioner against Judge Narciso A. Aquino and Aniceto Sandoval.
- Arceo acted as the administratrix of her deceased husband Honorato L. Arceo's intestate estate.
- On September 24, 1976, Arceo filed a motion to disqualify Judge Aquino from two cases:
- Special Proceeding No. 116-R (intestate estate of Honorato L. Arceo)
- Civil Case No. 283-R (suit against Aniceto Sandoval).
- The motion was based on the alleged close personal relationship between Judge Aquino and Sandoval, who was both a creditor in the intestate proceeding and a defendant in the civil case.
- Arceo claimed their association, particularly as members of the same Lions' Club, compromised the judge's impartiality.
- Judge Aquino denied the motion for recusal on the same day it was filed.
- Arceo's motion for reconsideration was also denied.
- On November 29, 1976, Arceo filed petitions for certiorari and prohibition to prevent Judge Aquino from hearing the cases.
- The petitions were given due course after the respondents submitted their comments and memoranda.
- Judge Aquino's application for disability retirement was approved, effective February 23, 1978, rendering the cases moot and academic.
Issue:
- (Unlock)
Ruling:
- The Supreme Court dismissed the petitions for certiorari and prohibition, upholding Judge Aquino's decision to remain in the cases.
- The Court ruled that the cases were ren...(Unlock)
Ratio:
- The Supreme Court emphasized the necessity for judges to be impartial and free from personal bias or interest.
- The issue of disqualification became moot following Judge Aquino's retiremen...continue reading
Case Digest (G.R. No. L-45121)
Facts:
The case involves Rosario P. Arceo as the petitioner against Hon. Narciso A. Aquino, the Judge of the Court of First Instance of Pangasinan, Branch XIV at Rosales, and Aniceto Sandoval as the respondents. The events leading to this case began when Rosario P. Arceo, acting as the administratrix of the intestate estate of her deceased husband, Honorato L. Arceo, filed a motion on September 24, 1976, seeking to disqualify Judge Aquino from presiding over two cases: Special Proceeding No. 116-R, concerning the intestate estate of Honorato L. Arceo, and Civil Case No. 283-R, which was a suit against Aniceto Sandoval. The basis for her motion was the alleged close personal relationship between Judge Aquino and Sandoval, who was both a creditor in the intestate proceeding and the defendant in the civil case. Arceo claimed that their association, particularly as members of the same Lions' Club, compromised the judge's impartiality. The motion for recusal was denied by Judge Aquino on the same day it was filed. Subsequently, Arceo filed a motion for reconsideration, reiterating her concerns about the judge's ability to maintain neutrality due to his relationship with Sandoval. This motion was also denied. On November 29, 1976, Arceo escalated the matter by filing petitions for certior...