Lescano v. Baes
REITERATIONFacts
The Antecedents: Petitioner Toribio Lescano filed an action in the Court of Agrarian Relations (CAR) against respondents Epifania Retizos and Nenita Amparo Lescano for the adoption of the leasehold system in lieu of their existing tenancy relationship. Procedural History: During the trial, petitioner alleged that the respondent judge, Juan A. Baes, demonstrated personal hostility and bias against his witness, Silvestre Masa, due to an administrative complaint filed by the witness against the judge. Petitioner filed a motion for disqualification, which was denied by the respondent judge. Upon appeal, the Court of Appeals sustained the denial. The Petition: Petitioner filed a petition for certiorari and prohibition with the Supreme Court, seeking the disqualification of respondent Judge Baes.
Issue(s)
Whether the petition for disqualification has become moot and academic. Whether the respondent judge demonstrated personal hostility and bias against the petitioner's witness.
Ruling
The petition is dismissed for having become moot and academic.
Ratio Decidendi
On the issue of mootness: The Court held that the petition had become moot and academic because the respondent Judge Juan A. Baes had already retired from the service upon reaching the age of compulsory retirement on December 27, 1974. Furthermore, the implementation of Presidential Decree No. 946 resulted in the transfer of CAR Case No. 2341 to the Court of Agrarian Relations, 8th Judicial District, Branch II, San Pablo City, which is now presided over by Judge Rodolfo F. De Gorostiza. Therefore, any further discussion on the alleged lack of fairness and impartiality of the respondent judge would be a pure academic exercise, serving no practical purpose. The Court emphasized that the purpose of judicial review is to provide a remedy for an existing grievance, and in this instance, no such grievance remained that could be addressed by the Court's decision. On the issue of personal hostility and bias: While the petition was dismissed on the ground of mootness, the Court implicitly acknowledged the procedural history of the case, which included the allegations of personal hostility and bias. However, due to the supervening events of the judge's retirement and the transfer of the case, the Court did not delve into the merits of these allegations. The Court's primary concern was to address the procedural posture of the case as presented, which had been rendered moot by subsequent developments. The Court's resolution focused on the procedural bar to further adjudication rather than a substantive ruling on the alleged bias.
Main Doctrine
A petition for certiorari and prohibition seeking the disqualification of a judge becomes moot and academic when the judge has already retired from the service and the case has been transferred to another court.