Case Digest (G.R. No. 221864)
Facts:
Celerna Calayag, et al. v. Sulpicio Lines, Inc., G.R. No. 221864, September 14, 2016, Supreme Court Second Division, Mendoza, J., writing for the Court. Petitioners are seventy-one survivors of the victims of the M/V Princess of the Stars (filed as consolidated civil cases for damages); respondent is Sulpicio Lines, Inc. (now Philippine Span Asia Carrier Corporation), originally joined by several owners, officers and crew. The petition to the Supreme Court assails the September 21, 2015 Decision and the December 18, 2015 Resolution of the Court of Appeals (CA) in CA-G.R. SP No. 138330, which ordered Judge Daniel C. Villanueva, Presiding Judge of the Regional Trial Court (RTC), Branch 49, Manila, to recuse from Civil Case Nos. 08-119709 to 09-121989.The litigation began with the sinking of the M/V Princess of the Stars on June 20, 2008 and ensuing 71 consolidated civil suits for damages by petitioners. During trial before Judge Villanueva, Sulpicio filed separate motions for inhibition alleging specific instances of bias and procedural irregularity: allowance of testimony on actual damages not pleaded; admission of a mere photocopy (a circular) despite objections under the Judicial Affidavit Rule and the Best Evidence Rule; acceptance of opinion testimony from an ordinary witness; active participation by the judge during cross-examination and discouraging counsel’s credibility-testing; prejudgment based on the company’s “notoriety”; and derogatory references to opposing counsel as a “saling-pusa” or “kibitzer.” Petitioners opposed the motions.
On September 2, 2014 Judge Villanueva denied the motions for inhibition, explaining his remarks were taken out of context and his rulings sought to prevent delay; reconsideration was denied. Sulpicio thereafter filed an original certiorari petition under Rule 65 before the CA alleging grave abuse of discretion. While that petition was pending, the RTC promulgated its decision on September 18, 2015 awarding damages to petitioners; Sulpicio filed a notice of appeal. On September 21, 2015 the CA granted Sulpicio’s certiorari petition, found that Judge Villanueva’s conduct and rulings cast doubt on his impartiality, ordered him to recuse and directed the records to be re-raffled. Petitioners’ motions for reconsideration before the CA were denied as moot in a December 18, 2015 Resolution, the CA explaining that the RTC’s subsequent decision rendered some aspects academic but nonetheless ordering the judge to refrain from further acts and transmit records for re-raffle.
Petitioners filed a Petition for Review on Certiorari under Rule 45 in the Supreme Court seeking to set aside the CA decisions. Subsequent events included Judge Villanueva’s May 11, 2016 O...(Subscriber-Only)
Issues:
- Procedural: Should petitioners’ Rule 45 petition be dismissed for failure to comply with documentary attachments and material-date requirements under Section 1, Rule 65 and Section 3, Rule 46 of the Rules of Court?
- Substantive: Did the Court of Appeals have sufficient grounds to order the inhibition (recusal) of Judge Villanueva from th...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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