Case Digest (G.R. No. L-55939)
Facts:
Florita Sardinia-Linco, Assistant Provincial Fiscal, Francisco Ma. Guerrero, Senior State Counsel, and People of the Philippines, Petitioners, vs. Honorable Gregorio G. Pineda, Judge of the Court of First Instance of Rizal, Gregorio Bilog, Jr., Amado Masicampo, Felino Cortez, Dominador Mateo, Tito Santos, Conrado Torres, Ricardo Maramot and Medardo Habal, Respondents, G.R. No. 55939, May 29, 1981, the Supreme Court En Banc, Teehankee, J., writing for the Court.The petitioners, Assistant Provincial Fiscal Florita Sardinia‑Linco and Senior State Counsel Francisco Ma. Guerrero, in their official capacities representing the State (the People of the Philippines being later deemed impleaded), assailed several orders issued by respondent Judge Gregorio G. Pineda in Criminal Case No. 27743 (anti‑graft case) pending in the Court of First Instance (CFI) of Pasig/Rizal. The petition sought certiorari, mandamus and prohibition to set aside: (a) the denial of their motion for the judge’s inhibition (orders of December 10, 1980 and January 6, 1981); (b) an order (January 7, 1981) declaring petitioners in contempt and imposing fines of P100 each; and (c) an order (January 12, 1981) terminating the prosecution’s rebuttal evidence, giving deadlines for submission of offers and memoranda and deeming the case submitted for decision.
The antecedents included an earlier Administrative Matter (No. 4453‑CFI) in which this Court (by resolution of December 18/28, 1979) had sustained Judge Pineda’s denial of a related motion for inhibition filed by another party; Chief Justice Fernando and Justices Teehankee and Melencio‑Herrera had dissented in that administrative action. While trial proceeded, petitioners filed a motion for Judge Pineda’s disqualification on August 25, 1980; the motion was initially stricken for caption defects and then refiled on August 28. At hearings on the disqualification motion, petitioner Guerrero testified and was cross‑examined; later, the judge ordered submission of the prosecution’s rebuttal evidence within prescribed short periods, and ultimately indicated the case was submitted. Petitioners claimed the judge displayed bias, improperly compelled Guerrero to testify at the inhibition hearing, wrongly held them in contempt based on a disputed interpretation of a letter by an Acting LRC Commissioner, and arbitrarily terminated the prosecution’s rebuttal opportunities.
The petition was brought to the Supreme Court as a petition for certiorari, mandamus and prohibition (with prayer for preliminary mandatory injunction). The Court considered memoranda‑opinions of Justices Teehankee and Fernandez, and the views recorded of other members; the People were ordered impleaded as petitioner but the Solicitor General was not required to file a comment. By resolution the Court (En Banc) set aside the January 12, 1981 order declaring the case su...(Pro-only)
Issues:
- Should the People of the Philippines be impleaded as petitioner and must the Solicitor General be required to comment before the Supreme Court acts?
- Did respondent Judge Gregorio G. Pineda commit grave abuse of discretion warranting his inhibition or disqualification from trying Criminal Case No. 27743?
- Did the respondent judge commit error or grave abuse by compelling petitioner Guerrero to testify and by permitting cross‑examination at the inhibition hearing?
- Was the January 7, 1981 contempt order against petitioners Linco and Guerrero valid and should it be set aside?
- Did the respondent judge err in terminating the prosecution’s rebuttal evidence,...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)