A.C. No. 2252-CFI - Ignacio vs. Valenzuela

The case involves Civil Case No. 7159-P, filed by Rufino Ignacio (complainant) against other parties, which included a prayer for damages and a request for a temporary restraining order to maintain the status quo pending the merits.
The restraining order was initially issued by the Executive Judge on May 2, 1979, with a hearing scheduled for May 4, 1979.

The case was raffled to Branch XXIX of the Court of First Instance of Rizal, presided over by Judge Manuel E. Valenzuela (respondent), despite his being on an approved vacation leave.
Documentation (New Judicial Form No. 86) confirmed that the respondent was on leave from May 1 to May 31, 1979, with handwritten notations on the calendar for other cases indicating “No hearing, Judge on vacation” or “No hearing, Judge on leave.”

On May 8, 1979, the respondent held a hearing in his chambers regarding the motion to quash the restraining order, despite being officially on vacation.

The hearing was conducted in the judge’s chambers with minimal formality—he was attired only in a polo jacket.
Only Civil Case No. 7159-P was heard on that day, while other cases scheduled for the same day were not heard due to the judge’s vacation status.

On May 9, 1979, immediately after the chamber hearing, the respondent granted the motion to quash the restraining order.

The respondent had applied for vacation leave covering May 1 to 31, 1979; however, he testified that he had not received notification of its approval until after the hearing.
Records, however, show that the vacation was approved on March 19, 1979, and notice sent on April 20, 1979, via ordinary mail—raising questions on the viability of his claim regarding the delayed receipt of notification.

After the issuance of the challenged order, Rufino Ignacio and co-plaintiffs questioned the legality of the respondent’s actions, which eventually led to appeal proceedings.
In the Court of Appeals case CA-G.R. No. 09226-SP, the appellate court upheld the respondent’s order on legal grounds, although the issue of propriety remained disputed.
Additional evidence surfaced indicating that the respondent later refused to recuse himself from another case involving the complainant, further implicating potential personal interest and partiality.

Whether the respondent Judge’s act of hearing and deciding the motion to quash the restraining order while on approved vacation rendered the decision invalid or improper.
Whether conducting the hearing in chambers while on leave, in casual attire, and canceling other scheduled cases, created an appearance of partiality or undue personal interest.

Whether the absence of a designated replacement judge or the extension of the respondent’s authority, even as a de facto judge, negated the impropriety of his conduct.
Whether the informal setting of the hearing (chamber hearing and casual dress) was admissible under the circumstances, given the parties’ apparent consent.

If the respondent’s conduct, regardless of the legal validity of the order, compromised the public’s confidence in the judicial system due to its appearance of impropriety.
Whether the timing and manner of the hearing suggested the judge was unduly influenced by personal interests in the case.