Case Digest (G.R. No. L-34756-59)
Facts:
In Mateo v. Villaluz (G.R. Nos. 34756–59, March 31, 1973), petitioners Manuel Mateo, Jr., Roberto Martinez alias Ruben Martinez, Enrique Concepcion, and Esmeraldo Cruz stood accused of robbery in band with homicide after an American Express Bank at Sangley Point, Cavite, was robbed and an American serviceman killed on June 4, 1971. Their complaints were assigned to Judge Onofre Villaluz of the Circuit Criminal Court, Seventh Judicial District. Following arraignment and motions to dismiss for insufficiency of evidence, the judge deferred resolution pending the prosecution’s presentation of evidence against a newly arrested suspect, Rolando Reyes. On October 1, 1971, Reyes executed an extrajudicial statement before Judge Villaluz implicating the petitioners. Upon Reyes’s separate trial, he repudiated that statement, claiming coercion by a government agent. Because the judge had attested to its due execution, petitioners moved to disqualify him for lack of objectivity. JuCase Digest (G.R. No. L-34756-59)
Facts:
- Underlying criminal proceedings
- On June 4, 1971, the American Express Bank at Sangley Point, Cavite, was robbed and an American serviceman killed.
- Four petitioners (Manuel Mateo, Jr., Roberto Martinez alias Ruben Martinez, Enrique Concepcion and Esmeraldo Cruz) were charged with robbery in band with homicide (Criminal Cases Nos. CCC-VII-843 to 846).
- Pretrial motions and confession
- Petitioners filed motions to dismiss for insufficiency of evidence and unconstitutional pretrial identification; Judge Villaluz deferred ruling pending presentation of evidence against another suspect.
- Rolando Reyes, later also indicted, executed an extrajudicial confession before Judge Villaluz implicating petitioners.
- Presentation of additional evidence and repudiation
- The trial court allowed the prosecution to present additional evidence; Reyes was called as an additional witness on February 3, 1972.
- Reyes repudiated his confession, alleging it was made under threat by a government agent; petitioners then moved to disqualify Judge Villaluz for inability to impartially adjudicate the repudiation.
- Motion to disqualify denied
- On February 12, 1972, Judge Villaluz refused to disqualify himself, prompting this petition for prohibition before the Supreme Court.
Issues:
- Disqualification under Rule 137
- Whether Judge Villaluz’s prior role in attesting Reyes’s confession, now repudiated, constitutes a valid discretionary ground for recusal.
- Whether his refusal to recuse is a “grave abuse of discretion” correctible by prohibition.
- Due process
- Whether the failure of an allegedly impartial tribunal to disqualify itself violated petitioners’ right to due process of law.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)