Case Summary (G.R. No. L-16509)

Background of the Case

• The case arises from Criminal Case No. 36042 in the Court of First Instance of Manila.
• The prosecution filed a petition for a writ of prohibition with a preliminary injunction against Hon. Bienvenido A. Tan, the presiding judge.
• The petition sought to prevent the judge from continuing to preside over the criminal case involving multiple respondents for violations of Section 16 of Republic Act No. 85.

Grounds for the Petition

• The prosecution argued that the judge should inhibit himself from the case due to a prior decision he rendered in Civil Case No. 24248.
• The civil case involved the same parties and transactions as the criminal case, suggesting that the judge had already formed an opinion on the merits of the criminal case.
• The prosecution contended that this prior involvement created a conflict of interest, warranting the judge's disqualification.

Court's Initial Response

• Following the filing of the petition, the Supreme Court issued a writ of preliminary injunction to temporarily halt the proceedings in the criminal case.
• This action indicated the Court's recognition of the potential merit in the prosecution's concerns regarding the judge's impartiality.

Mootness of the Issue

• The situation changed when it was revealed that Hon. Bienvenido A. Tan had retired from the bench.
• As a result of the judge's retirement, the issue of his ability to preside over the case became moot.
• The Supreme Court determined that there was no longer a need to address the merits of the petition since the judge was no longer in a position to hear the case.

Conclusion and Dismissal

• The Supreme Court dismis...continue reading