A.M. No. RTJ-02-1699 - Umali-Paco vs. Quilala

Reinato G. Quilala – Presiding Judge, Regional Trial Court (RTC) Branch 57, Makati City.
Aida C. Lomugdang – Acting Clerk of Court.
Lilia N. Batu – Court Stenographer.

An administrative complaint was filed against the respondents in connection with Civil Case No. 01-112 (PRAMA vs. PRA).
The complaint stemmed from allegations that the conduct of the respondents during hearings exhibited bias, partiality, and disregard for established procedural rules.

Alleged to have coached or led witness Ramon Collado during his testimony.
Granted PRAMA’s motion to set an earlier hearing without affording PRA an opportunity to oppose.
Remarked that he could issue a writ of preliminary injunction ex parte, implying a unilateral resolution of the matter.
Interrupted and disregarded the observations of complainant counsel Atty. Vernette Umali-Paco.
Displayed a pattern of conduct later evidenced by issuing orders that appeared favorable to PRAMA and prejudicial to PRA.

Delegated the task of receiving evidence and ruling on objections during the hearing, a duty reserved for judges under the Rules of Civil Procedure.
Performed these functions despite not being a member of the bar, in contravention of Section 9, Rule 30, of the 1997 Rules of Civil Procedure.

Allegedly manipulated the stenographic record by making it appear that Judge Quilala was present during a hearing when he was not.
Recorded rulings and statements in a manner that obscured the true course of the proceedings.

The hearings involved distinct sessions (morning and afternoon) during which procedural irregularities were noted.
Testimonies and affidavits (e.g., from Josephine Vigden and counsel Dolores Rigonan) corroborated the complainants’ claims regarding the judge’s absence and the irregular delegation of duties.
Investigating Justice Edgardo F. Sundiam noted that although judicial intervention in questioning a witness is within discretion, such conduct should be minimal to avoid the appearance of partiality.
The controversy also included the non-compliance with procedural rules when evidence was received by a non-bar member and the subsequent tampering with official records.

Whether Judge Quilala’s conduct during hearings—specifically his intervention in questioning the witness, his coaching of the witness, and his unilateral decision to schedule an earlier hearing—constituted bias or partiality in favor of PRAMA over PRA.
Whether his remarks about the potential issuance of a writ ex parte contributed to an appearance of impropriety.

Whether the delegation of the duties (receipt of evidence and ruling on objections) to Acting Clerk Aida C. Lomugdang, who is not a member of the bar, violated Section 9, Rule 30 of the 1997 Rules of Civil Procedure.
Whether the alteration of the stenographic record by Lilia N. Batu compromised the integrity of the official record.

Whether the judge’s conduct, including interrupting counsel and displaying a confrontational tone, fell short of the requisite judicial decorum and contributed to the perception of bias.
Whether the actions taken during the proceedings, though argued to be within judicial discretion, nonetheless violated the ethical and procedural standards expected of a judge.