Case Summary (G.R. No. 209370)
Applicable Law
The 1987 Philippine Constitution, alongside Rule 137, Section 1 of the Rules of Court, governs the conduct and disqualification of judges. Additionally, Article 32 of the Civil Code pertains to the accountability of public officers for certain violations of rights and liberties.
Allegations and Grounds for Motion
Atty. Aparicio filed a Motion for Inhibition, asserting reasons for the judge's disqualification related to alleged hostility stemming from prior administrative actions against Judge Andal. Despite the absence of explicitly stated grounds within the motion, it referenced a letter from the Supreme Court regarding an internal matter.
Judicial Response
Judge Andal refused to inhibit himself, stating that the motion lacked valid grounds as confirmed by the parties involved in the ongoing cases. He noted that the form of the request did not showcase any significant bias, and he intended to continue with his judicial duties without yielding to the petitioner’s demands.
Limits of Judicial Disqualification
The Court emphasized that a judge is disqualified from a case only in circumstances where there exist substantial grounds for disqualification, such as a direct pecuniary interest or familial relations with parties involved. In this case, no such valid grounds were provided in Atty. Aparicio's motion.
Presumption of Impartiality
The Court found the assertions of hostility and bias against Judge Andal to be unfounded. It held that a mere assumption of prejudice resulting from Atty. Aparicio's earlier administrative complaints does not warrant a presumption of impartiality on the judge's part.
Judge's Authority and Conduct
Having assessed the conduct of Judge Andal, the Court concluded that his decision to deny the Motion for Inhibition and to proceed with all cases was both lawful and within his scope of authority. The absence of a restraining order further legitimized his continuance in adjudicating the pending matters.
Bar of Judicial Liability
In addressing the damages sought against Judge Andal under Article 32 of the Civil Code, the Court distinguished that judges are typically shielded from liability in the performance of their judicial functions, provided their actions do not constitute penal violations. The judge’s decisions in this case were performed within a legal framework and did not breach any penal code.
Professional Conduc
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Case Background
- Petitioner: Atty. Lolito G. Aparicio
- Respondents: Hon. Ermelindo C. Andal, Presiding Judge of the Regional Trial Court, Branch 27, Tandag, Surigao del Sur; The Republic of the Philippines; The National Treasurer; The Commission on Audit; and other relevant government entities.
- Nature of the Case: Special civil action for certiorari, prohibition, and mandamus, concerning the denial of the petitioner’s Motion for Inhibition.
- Relevant Dates: Orders being assailed were dated October 11 and 12, 1988; the petition was filed on September 26, 1988.
Motion for Inhibition
- Petitioner filed a Motion for Inhibition requesting Judge Andal to recuse himself from all cases involving the petitioner as counsel or party litigant.
- The motion was based on a letter from the Supreme Court's Deputy Court Administrator, suggesting potential bias due to prior administrative cases filed by the petitioner against Judge Andal.
- The motion lacked explicit valid grounds but implied an existing state of hostility between the petitioner and the judge.
Judge Andal's Response
- Judge Andal denied the Motion for Inhibition, stating it lacked valid grounds.
- He asserted that he was unaware of the administrative cases against him at the time of the denial.
- Judge Andal expressed that he did not harbor any personal resentment against the petitioner and maintained a focus on his judicial responsibilities.
Key Legal Issues
- Whether Judge Andal's denial of the Motion for In