Case Digest (G.R. No. L-34756-59)
Facts:
- The case "Mateo, Jr. v. Villaluz" involves petitioners Manuel Mateo, Jr., Roberto Martinez alias Ruben Martinez, Enrique Concepcion, and Esmeraldo Cruz.
- They were being tried by Judge Onofre Villaluz for robbery in band with homicide.
- The incident occurred on June 4, 1971, at the American Express Bank in Sangley Point, Cavite, resulting in the death of an American serviceman.
- Four criminal cases were filed against the petitioners, docketed as Criminal Cases Nos. CCC-VII-843 to 846, Cavite.
- Judge Villaluz was assigned to these cases and ordered the preliminary investigation.
- Mateo, Jr. and Cruz were arraigned on June 24, 1971.
- Martinez filed a motion to dismiss due to insufficient evidence and unconstitutional pre-trial identification.
- The prosecution opposed the motion, and the judge deferred ruling on it until after the prosecution presented evidence against another suspect, Rolando Reyes.
- Reyes had made an extrajudicial statement implicating the petitioners, which he later repudiated, claiming it was made under threat by a government agent.
- The petitioners filed a motion for the disqualification of Judge Villaluz, arguing his involvement in the extrajudicial statement compromised his impartiality.
- Judge Villaluz denied the motion, leading to the petition for prohibition before the Supreme Court.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled in favor of the petitioners.
- The Court granted the petition for prohibition and issued a permanent restraining order against Judge Villaluz.
- The Court found that the judge's failure to disqualify him...(Unlock)
Ratio:
- The Court emphasized the fundamental requirement of due process, which necessitates an impartial and disinterested tribunal.
- Judge Villaluz's involvement in the extrajudicial statement of Rolando Reyes, which was later repudiated, created a situation where his objectivity could be ...continue reading
Case Digest (G.R. No. L-34756-59)
Facts:
The case of "Mateo, Jr. v. Villaluz" involves petitioners Manuel Mateo, Jr., Roberto Martinez alias Ruben Martinez, Enrique Concepcion, and Esmeraldo Cruz, who were being tried by respondent Judge Onofre Villaluz for the offense of robbery in band with homicide. The incident in question occurred on June 4, 1971, when the American Express Bank at Sangley Point, Cavite, was robbed, resulting in the death of an American serviceman. Four criminal actions were filed against the petitioners, docketed as Criminal Cases Nos. CCC-VII-843 to 846, Cavite. The cases were assigned to Judge Villaluz, who also ordered the preliminary investigation. Petitioners Mateo, Jr. and Cruz were arraigned on June 24, 1971, while Martinez filed a motion to dismiss on grounds of insufficient evidence and unconstitutional pre-trial identification. The prosecution opposed the motion, and the judge deferred ruling on it until after the prosecution presented its evidence against another suspect, Rolando Reyes. Reyes had executed an extrajudicial statement implicating the petitioners, which he later repudiated, claiming it was made under threat by a...