G.R. No. 171247 - Villamor, Jr. vs. Manalastas

Leonardo S. Umale (respondent) filed a complaint against Alfredo L. Villamor, Jr. (petitioner) and others with the RTC of Pasig City, seeking to compel Villamor to account for and deliver rental payments allegedly held by him.
The case was initially raffled to RTC Branch 155, presided by Judge Luis R. Tongco, who inhibited himself upon respondent's motion.
The case was re-raffled to RTC Branch 268, presided by Judge Amelia C. Manalastas.

Petitioner filed multiple Motions for Inhibition against Judge Manalastas based on alleged bias, citing:

That Judge Manalastas and the respondent stood as godparents to a child of a common friend.
That Judge Manalastas’s husband’s law firm wrote to petitioner on claims similar to those in respondent's complaint.

Judge Manalastas denied these motions in an Omnibus Order dated October 17, 2005, stating the allegations were insufficient to overcome the presumption of impartiality.

Petitioner filed a Petition for Certiorari with the Court of Appeals (CA), assailing the denial of his Motions for Inhibition but excluding other alleged errors by Judge Manalastas, which were subject to a separate Motion for Reconsideration (MR) with Motion to Lift Order of Default filed in the RTC.
Both parties filed various manifestations and motions before the CA, including respondent’s motion to dismiss the petition on grounds of forum shopping.
Petitioner filed a Motion for Inhibition on Account of Administrative Case at the RTC after filing an administrative complaint for gross ignorance of the law, bias, and partiality against Judge Manalastas.
The Petitioner also informed the CA of the administrative complaint filed against Judge Manalastas.

The CA dismissed the Petition for Certiorari on January 31, 2006, on grounds of forum shopping.
The CA found that petitioner had pending remedies—MR with Motion to Lift Default Order in RTC, the Petition for Certiorari with CA, and the Motion for Inhibition on Account of Administrative Case in the RTC—all praying for essentially the same relief.
The CA held that filing multiple remedies based on the same causes against the same judge constituted forum shopping.

Petitioner filed a petition before the Supreme Court seeking to reverse the CA resolution.
Respondent argued the sole issue of petitioner’s forum shopping conduct.
Petitioner requested the Court to address both forum shopping and the propriety of Judge Manalastas’s refusal to inhibit herself.
The administrative complaint against Judge Manalastas remained unresolved at the time of the Supreme Court petition.

Whether Judge Manalastas’s decision to continue hearing the civil case was improper.