G.R. No. 52080 - Government Service Insurance System vs. Court of Appeals

The controversy arises from Special Proceeding Case No. 704-R, “In the Matter of the Intestate Estate of the Late Gelacio Munsayac, Sr. and the Late Vicenta Munsayac.”
Petitioners – Grace F. Munsayac-De Villa, Lily F. Munsayac-Sunga, and Roy Peter F. Munsayac – are three of the five children of the late spouses and filed the case seeking letters of administration by nominating De Villa as administratrix.
The nomination was opposed by the two remaining children, Gelacio F. Munsayac, Jr. and the late Nora F. Munsayac-Visperas (represented by her heirs), who opposed petitioners’ nomination by nominating Munsayac, Jr. as administrator.
Munsayac, Jr. was eventually appointed administrator, replacing Lawyer Ceasar G. Oracion as special administrator, which set the stage for further disputes.

The special proceeding was filed on November 17, 1998 and was later subjected to a 60-day suspension to explore an amicable settlement between the opposing siblings.
Despite the pause, contentious pleadings ensued and complicated the settlement process.
Efforts by petitioners to inhibit the then-presiding Judge Antonio C. Reyes complicated the matter and led to further judicial interventions.

On September 28, 1999, petitioners filed a Request for Inhibition against Judge Reyes due to his alleged conduct.
A week later, petitioners escalated the matter by filing a petition for certiorari, prohibition, and mandamus (CA-G.R. SP No. 55193), challenging Judge Reyes’ orders—including one compelling De Villa to produce bank time deposit certificates/documents and a related arrest order for her non-compliance.
An administrative case was filed on July 11, 2000 before the Supreme Court, calling for the suspension and eventual removal of Judge Reyes on grounds of grave misconduct and inefficiency.

On May 4, 2000, Judge Reyes issued an order under an omnibus motion instructing petitioners to surrender specific bank deposits and jewelry; the amount for the bank investment was noted as P13,506,343.33 (with legal interest) and additional sums for other amounts described in detail.
Subsequent orders followed:

The June 22, 2000 order ordered the immediate arrest of petitioners for failure to comply with the surrender order.
The August 28, 2000 order reiterated the earlier surrender requirements and confirmed that the arrest order would remain in force until full compliance.

The Court of Appeals, in a separate decision concerning the Extrajudicial Partition among the heirs, terminated Special Proceeding No. 704-R as the partition was deemed the “final, complete and absolute settlement” of their respective shares.
With the termination of the main proceedings, the rationale for the pending inhibition petition and related orders (such as the freeze on bank certificates and the custodia legis) became collateral issues.

The central issue raised by petitioners was whether Judge Reyes should be inhibited for alleged vindictiveness, arbitrariness, prejudice, and bias, thus denying them the right to an impartial tribunal.

Petitioners argued that the judge’s actions in ordering an arrest without a proper written charge and hearing, as well as his handling of the estate proceedings, warranted his inhibition from further involvement.
They further contended that with pending issues such as the freeze order affecting bank deposits and jewelry, removal of the judge was necessary to ensure fairness.