Case Summary (A.M. No. RTJ-02-1699)
Charges of Bias and Partiality
The complainants accused Judge Quilala of bias and partiality on several grounds, including:
- Coaching a witness for PRAMA.
- Granting a motion by PRAMA to expedite a hearing without giving PRA an opportunity to oppose.
- Indicating an intention to issue a writ ex parte during a hearing.
- Interrupting and dismissing Atty. Vernette Umali-Paco during her statements in court.
Actions Taken by Respondent Judge
On multiple occasions, the complainants alleged that Judge Quilala exhibited behavior indicating favoritism towards PRAMA. This included leading and coaching the witness Ramon Collado during testimonies and issuing an order to set a hearing with haste, potentially infringing upon PRA's right to due process. The judge also remarked in a hearing that he could issue an injunction ex parte, implying he might decide in favor of PRAMA without hearing PRA's evidence.
Defense by Respondent Judge
In his comment, Judge Quilala defended his actions, suggesting that the court’s practice allowed for judges to ask clarifying questions of witnesses to expedite proceedings. He maintained that his actions did not constitute bias and that he still adhered to due process in acknowledging the arguments from both parties.
Alleged Procedural Violations
Further violations were reportedly seen when Judge Quilala delegated evidence reception to Clerk Lomugdang, who was not a lawyer, which contravened Section 9, Rule 30 of the 1997 Rules of Civil Procedure that stipulates evidence must be received by a judge or a bar member. This resulted in procedural errors and issues with the transcripts, notably when Stenographer Batu inaccurately recorded that Judge Quilala was present and presiding during sessions he did not attend.
Evaluations and Recommendations
An investigation led by Associate Justice Edgardo F. Sundiam concluded that while Judge Quilala deviated from regular practices, bias and partiality could not be conclusively inferred from his actions. His interventions may have been attempts to clarify testimonies from witnesses struggling with language barriers. However, concerns were raised regarding his decorum, particularly in how he addres
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Background of the Case
- Complainants Vernette Umali-Paco, Bernardino D. Ng, Orlando H. Habitan, and Josephine F. Andrada filed an administrative complaint against Judge Reinato G. Quilala, acting Clerk of Court Aida C. Lomugdang, and Court Stenographer Lilia N. Batu.
- The complaint arose from their involvement in Civil Case No. 01-112, where the Philippine Retirement Authority (PRA) was the defendant in an action for specific performance brought by the Philippine Retirement Authority Members Association Foundation, Inc. (PRAMA).
- The complaint was referred to Associate Justice Edgardo F. Sundiam of the Court of Appeals for investigation and recommendations.
Allegations Against Respondents
- The complainants accused Judge Quilala of bias and partiality on multiple occasions:
- Leading and coaching witness Ramon Collado during the hearing for a writ of preliminary injunction.
- Granting PRAMA's motion to set an earlier hearing without allowing PRA an opportunity to oppose.
- Indicating he could issue a writ of preliminary injunction ex parte during a hearing.
- Interrupting Atty. Vernette Umali-Paco while she was explaining a matter in court.
Specific Incidents Cited
- On March 6, 2001, Judge Quilala allowed PRAMA to set a hearing without opposition from PRA.
- During the March 20, 2001 hearing, he suggested that he could issue a writ without considering PRA’s evidence.
- Evidence was received