Title
Parayno vs. Meneses
Case
G.R. No. 112684
Decision Date
Apr 26, 1994
Mayoralty and councilors' election protests; judge's voluntary inhibition deemed improper, ordered to proceed with case resolution promptly.

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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