Factual Background
On 22 October 1992, petitioner Parayno filed a motion for inhibition against Judge Villanueva. The court promptly granted the motion. After the records of Case No. U-5346 were forwarded to the Executive Judge, the latter, by order dated 26 October 1992, directed the assignment of the case to Branch 46, but only after the presiding judge there, Hon. Roger Domagas, agreed to hear and try the case.
Petitioner Parayno challenged the assignment as improper. The Court issued a temporary restraining order and remanded the matter to the Court of Appeals for proper disposition. The Court of Appeals set aside the order of 26 October 1992, directing that the Executive Judge include the case in the regular raffle for reassignment. The case was then re-raffled to Branch 49, the same branch where the councilors’ protests were pending.
In the councilors’ protest, the revision of ballots was underway by 21 October 1993, with private respondent Lorenzo Mateo filing a “Motion to Use Revision Committee Report Blank Form.” During the revision on 21 October 1993—specifically in the afternoon—private respondent Mateo, in open manifestation, made of record that the trial presiding judge of Branch 49 was also the trial judge in the electoral protest case U-5346 (Parayno versus Mateo, as stated in the transcript), and he expressed the view that the situation created a degree of greater sympathy on the part of the trial presiding judge toward the protestee.
Issuance of the Assailed Orders
The following day after Mateo’s manifestation, respondent judge issued the assailed order inhibiting himself from further hearing the two election cases. Petitioners moved for reconsideration, but the respondent judge denied the motion by an order dated 16 November 1993. Petitioners thereafter filed the present petition for certiorari.
The Parties’ Contentions
Petitioners argued that the respondent judge’s inhibition lacked legal basis and was improper. They maintained that the circumstances did not satisfy the conditions for disqualification under Section 1, Rule 137, and that voluntary inhibition could not be justified by tenuous allegations of partiality unmoored from sound ethical or legal grounds.
In response, respondent judge acceded to the inhibition triggered by private respondent’s manifestation that the same trial judge handled the related electoral protest and that this created perceived sympathy toward the protestee.
Legal Basis and Reasoning
The Court anchored its ruling on Section 1, Rule 137 of the Rules of Court, which provides that no judge or judicial officer shall sit in any case where he, or his spouse or child, is pecuniarily interested; or where he is related to either party within the sixth degree of consanguinity or affinity; or related to counsel within the fourth degree; or where he previously acted as executor, administrator, guardian, trustee, or counsel; or where he had presided in any inferior court when his ruling or decision is the subject of review, without the written consent of all parties in interest.
The Court further emphasized that the rule’s purpose was to ensure judicial freedom from inclinations or prejudices and the capacity to render a just and independent judgment. It held that due process requires not only actual lack of bias but also that the judge appear to be free from bias. The Court reiterated that impartiality is a state of mind, so it requires some manifestation of its reality. While Section 1, Rule 137 also recognizes that a judge may, in the exercise of sound discretion, disqualify himself for just and valid reasons other than those enumerated, the Court stressed that voluntary inhibition must rest on good, sound, or ethical grounds or just and valid reasons. It was not enough that a party leveled tenuous allegations of partiality; the judge still bore the sacred duty to administer justice without fear or favor.
Applying these principles, the Court found the basis for inhibition to be defective. The trigger for inhibition was private respondent Mateo’s manifestation during ballot revision that the presiding judge in Branch 49 was also the trial judge in the other electoral protest case and that, in the protestant’s view, this suggested greater sympathy. Th
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Parties and Procedural Posture
- Rodolfo E. Parayno served as the incumbent Municipal Mayor of Urdaneta, Pangasinan, and he petitioned for certiorari.
- The other petitioners, namely Clemartin B. Arboleda, Eduardo R. Perez, Casimiro C. Carancho, Diosdado T. Samson, Maximo G. Sumera, and Marcelino M. Dela Cruz, were members of the Sangguniang Bayan who, together with Parayno, were the protestees in separate pending election protests.
- The respondents were Hon. Iluminado Meneses, Presiding Judge, Branch 49, Regional Trial Court, First Judicial Region, Urdaneta, Pangasinan, and the individual counselors Lorenzo M. Mateo, Arturo E. Estrada, Norma Lustina, and Pablo Mercado.
- The petition sought to set aside two RTC orders dated 22 October 1993 and 16 November 1993, where the respondent judge voluntarily inhibited himself and denied petitioners’ motion for reconsideration.
- The election protests were pending with the RTC at the time of the petition, and the matter reached the Court through certiorari to nullify the inhibition-related orders.
Key Factual Allegations
- The mayoralty protest (docketed Case No. U-5346) involved Parayno and was originally raffled to Branch 45 of the RTC, then presided over by Judge Manuel Villanueva.
- The councilors’ protest (docketed Case No. U-5347) involved the other petitioners and was assigned to Branch 49 of the RTC, with Judge Iluminado Meneses presiding.
- On 22 October 1992, petitioner Parayno filed a motion for the inhibition of Judge Villanueva, which the RTC promptly granted.
- After the records of Case No. U-5346 were forwarded to the Executive Judge, the Executive Judge directed assignment to Branch 46, but only after the presiding judge (Hon. Roger Domagas) agreed to hear and try the case.
- Parayno assailed the assignment as improper, and the Court issued a temporary restraining order and remanded the matter to the Court of Appeals.
- The Court of Appeals set aside the Executive Judge’s order of 26 October 1992 and directed the Executive Judge to include Case No. U-5346 in the regular raffle for re-assignment.
- As a result, Case No. U-5346 was re-raffled to Branch 49, where the councilors’ protest (Case No. U-5347) was then pending.
- In Case No. U-5347, the revision of ballots was in progress during the afternoon of 21 October 1993, and the private respondent Lorenzo Mateo (as protestant) was the Revisor for the protestants-councilors in the revision committee.
- During the revision on 21 October 1993, Mateo manifested that the trial presiding judge of Branch 49 was the same trial judge in Case No. U-5346 (Parayno versus Mateo), which the protestant perceived as indicating greater sympathy of the trial presiding judge toward the protestee.
- The next day, respondent judge issued the assailed order inhibiting himself from further hearing both cases.
- The judge denied the petitioners’ motion for reconsideration, prompting the filing of the certiorari petition.
Statutory Framework
- The Court applied Section 1, Rule 137 of the Rules of Court on disqualification of judges.
- Rule 137, Section 1 prohibits a judge from sitting in a case when he, or his wife or child, is pecuniarily interested, or when he is related to a party or counsel within the specified degrees, or when he previously served in specified capacities, including when he presided in any inferior court whose ruling is subject of review, absent written consent of all parties in interest.
- The Court recognized that a judge may also, in the exercise of sound discretion, disqualify himself for just or valid reasons other than those mentioned above.
- The Court emphasized that the underlying purpose of judicial disqualification rules is to ensure that a judge remains free from