Go v. Villaluz
REITERATIONFacts
The Antecedents: Petitioner Apolonia Angeles Go believed that respondent Judge Onofre A. Villaluz displayed excessive zeal in investigating a complaint for estafa against her and issuing a warrant of arrest. Petitioner alleged that this indicated a pre-judgment of the case, preventing her from expecting justice from the respondent Judge. Procedural History: Petitioner sought the disqualification of respondent Judge Villaluz. A restraining order was issued by the Supreme Court. Respondents filed a memorandum arguing that the issue of disqualification was premature as petitioner had not first requested the judge to inhibit himself. The Petition: Petitioner filed a manifestation stating that respondent Judge Villaluz had inhibited himself from further trying and deciding the case, rendering the matters involved moot and academic. The judge's order of inhibition cited the preliminary examination and investigation conducted by his court and the cases of Umale v. Villaluz and Mateo, Jr. v. Villaluz.
Issue(s)
Whether the issue of the respondent Judge's alleged pre-judgment and disqualification has become moot and academic. Whether the petition for certiorari and prohibition should be dismissed.
Ruling
The petition for certiorari and prohibition is dismissed. The records of the case are remanded to the Court of First Instance of Rizal for appropriate action.
Ratio Decidendi
On the issue of whether the petition has become moot and academic: The Supreme Court held that the voluntary inhibition of respondent Judge Onofre A. Villaluz from further trying and deciding the case rendered the matters involved purely legal technical questions that were moot and academic. The judge's order of inhibition explicitly stated that he was inhibiting himself pursuant to Section 1, par. 2, Rule 137 of the New Rules of Court and in accordance with the cases of Umale v. Villaluz and Mateo, Jr. v. Villaluz. These cited cases underscore the principle that a judge who conducted the preliminary examination and investigation should be mindful of the standard of strict neutrality. The judge's act of forwarding the records for the Supreme Court's disposition further supported the conclusion that the original grievance was resolved by his own action. Therefore, the petition, which sought his disqualification, no longer presented a live controversy requiring adjudication on the merits of the alleged pre-judgment. On the dismissal of the petition: As the issues were rendered moot and academic by the respondent Judge's inhibition, the Supreme Court granted the prayer in the petitioner's manifestation. The petition for certiorari and prohibition was dismissed. The Court ordered the remand of the records to the Court of First Instance of Rizal for the Executive Judge to take the necessary steps to have the case raffled and proceeded with in accordance with the Rules of Court. This disposition effectively returned the case to the regular judicial process, with a new judge to be assigned, thereby obviating the need for the Supreme Court to rule on the merits of the disqualification issue.
Main Doctrine
A petition for certiorari and prohibition seeking the disqualification of a judge becomes moot and academic when the judge voluntarily inhibits himself from trying the case, rendering the issues purely legal technical questions.