Case Summary (G.R. No. 127262)
Case Background and Charges
The petitioners were charged with the crimes of rape with homicide, specifically for the alleged rape of Carmela Vizconde and the murders of Carmela, her mother Estrellita, and sister Jennifer. The incident reportedly occurred at the Vizconde residence in Parañaque in the late evening of June 29 to early morning of June 30, 1991. The criminal case (Criminal Case No. 95-404) was assigned to Branch 274 of the Regional Trial Court of Parañaque, presided over by Judge Amelita G. Tolentino.
Motions for Judicial Disqualification and Arraignment
Prior to arraignment, petitioners Webb and co-accused Gerardo Biong filed motions for the disqualification or inhibition of Judge Tolentino alleging bias and partiality. These contentions included the judge’s reported media statements suggesting guilt based on the accused’s failure to surrender and comments on their conditions in custody. All such motions were denied by the judge. Petitioners were arraigned on September 4, 1995.
Evidentiary Issues and Judicial Orders during Trial
During the bail hearings and trial, significant issues arose regarding evidence and witness testimony. The prosecution’s key witness, Jessica Alfaro, identified petitioners as perpetrators. Defense counsel sought to impeach her credibility via contradictory affidavits executed in April and May 1995. The prosecution objected to cross-examination on the April affidavit arguing its inadmissibility under the constitutional right to counsel (Article III, Section 12(1) and (3), 1987 Constitution), since it was not executed in the presence of counsel. The trial judge sustained these objections and prohibited cross-examination on that affidavit’s contents.
Defense efforts to establish Alfaro’s motives, including questions about her family members and educational background, were also curtailed pursuant to relevancy objections upheld by the trial court. The petitioners renewed motions to disqualify Judge Tolentino due to alleged prejudice, but these were denied for lack of merit.
Appeals to the Court of Appeals and Supreme Court Intervention
Petitioners filed petitions for certiorari with the Supreme Court challenging various rulings, including denial of hospitalization, inadmissibility of Alfaro’s April 28 affidavit, and motions for inhibition. The Supreme Court referred the matter to the Court of Appeals for disposition.
The Court of Appeals reversed the order excluding Alfaro’s April 28 affidavit but denied other reliefs. It also denied the motions for Judge Tolentino’s inhibition. Petitioners moved for reconsideration, which the Court of Appeals denied.
Subsequently, petitioners filed the present petition assailing the Court of Appeals’ rulings and asserting that the trial judge demonstrated bias and prejudice through adverse rulings, rejection of evidence, and conduct such as visiting the Vizconde residence. They argued such bias compromised their right to a fair trial by an impartial judge.
Legal Principles on Judicial Disqualification and Due Process
The Supreme Court reiterated that the constitutional guarantee of due process under the 1987 Constitution requires that every accused be tried by an impartial and disinterested tribunal. A judge should voluntarily inhibit himself or be disqualified upon valid grounds, including bias, prejudice, pecuniary interest, or relationship within certain degrees to the parties or counsel (Rule 137, Section 1, Revised Rules of Court).
However, the burden to prove bias and prejudice is heavy and requires clear and convincing evidence, preferably extrajudicial in origin. Adverse or erroneous judicial rulings within the trial, no matter how numerous or unfavorable, do not alone constitute bias or prejudice warranting disqualification. Instead, such rulings must stem from an extraneous source or demonstrate malice or bad faith. The Court further clarified that trial courts inevitably err, and erroneous rulings do not equate to lack of impartiality.
Application to the Case and Ruling
The petitioners failed to provide extrinsic evidence proving that Judge Tolentino acted with malice or bias. Their claims relied mainly on a series of adverse rulings, which are insufficient to establish judicial prejudice. Notably, an erroneous ruling related to the rejection of 132 pieces of evidence was subsequently corrected, with the judge admi
...continue readingCase Syllabus (G.R. No. 127262)
Nature and Background of the Case
- Petitioners Hubert Webb, Antonio Lejano, Hospicio Fernandez, Miguel Rodriguez, Peter Estrada, and Michael Gatchalian challenged the Court of Appeals decision dated June 21, 1996, and its resolution dated November 15, 1996.
- The petitions involved Criminal Case No. 95-404, where the petitioners were charged with rape with homicide involving the rape and killing of Carmela Vizconde, her mother Estrellita, and sister Jennifer in their Parañaque home from June 29-30, 1991.
- The case was raffled to Branch 274 of the Regional Trial Court (RTC) of Parañaque, presided over by Judge Amelita G. Tolentino.
- The petitioners sought the disqualification (inhibition) of Judge Tolentino alleging bias and prejudice.
- Multiple motions for disqualification were filed by the petitioners and Gerardo Biong (a co-accused originally included), but all motions were denied by Judge Tolentino.
- The petitioners also filed various motions such as motions for bail, motion for hospitalization, and motions concerning the admissibility of evidence during the trial.
Key Procedural History and Judicial Actions
- Petitioners were arraigned on September 4, 1995, and filed separate petitions for bail, all denied eventually.
- A core battleground during pre-trial was the admissibility and cross-examination of Jessica Alfaro, a principal prosecution witness who identified the accused.
- The respondent judge denied cross-examination on Alfaro’s April 28, 1995 affidavit on grounds of inadmissibility due to absence of counsel during execution, citing Article III Section 12(1) and (3) of the 1987 Constitution.
- The defense attempted to impeach Alfaro’s credibility by exposing inconsistencies and her alleged motive based on family background, but many of the defense’s questions and evidence were disallowed by Judge Tolentino.
- On October 1, 1996, Judge Tolentino admitted only 10 of 142 offered exhibits by the defense, eventually reversing the rejection of 132 exhibits after further trial developments.
- The respondent judge ordered an ocular inspection of the former Webb residence to verify testimony about a secret door despite objections.
- A motion for depositions of witnesses residing in the U.S. was denied for failure to prove inability of witnesses to appear at trial.
- The Court of Appeals partially reversed the ruling disallowing Alfaro’s April 28 affidavit but otherwise denied relief to the petitioners.
- The petitioners filed the present petition before the Supreme Court seeking disqualification of the judge on grounds of bias, denial of rights to fair trial, and erroneous rulings leading to prejudice.
Core Issue: Disqualification of Judge for Alleged Bias and Prejudice
- The fundamental question was whether Judge Amelita G. Tolentino should inhibit herself due to alleged bias and prejudice in conducting Criminal Case No. 95-404.
- The Court emphasized that due process under th