Joaquin v. Barretto
REITERATIONFacts
The Antecedents: Constancio Joaquin filed an action for mandamus against Judge Alberto Barretto, seeking to compel him to proceed with the trial of a case pending before him, wherein the plaintiff sought a license to operate a cockpit. Judge Barretto had voluntarily disqualified himself from hearing the case. Procedural History: This Court previously issued a decision in the mandamus action, setting aside the order of disqualification and requiring Judge Barretto to proceed with the trial. An order was issued and served upon him. The Petition: Subsequently, when the case was called for trial, Judge Barretto had been temporarily relieved, and Judge Jose C. Abreu was appointed to hold court in his place. The plaintiff's attorneys objected, arguing that only Judge Barretto could lawfully hear the case, as the original mandamus order was directed to him personally. The present motion seeks to clarify the dispositive part of the Court's decision and the order issued thereon, addressing the perceived ambiguity regarding whether any judge other than Judge Barretto could hear the case without violating the order.
Issue(s)
Whether the order of mandamus directing Judge Alberto Barretto to proceed with the trial of a case is rendered ineffective or ambiguous by his temporary relief and substitution by another judge. Whether the trial of the case can lawfully proceed before a judge other than Judge Alberto Barretto.
Ruling
The motion for clarification is denied. The Court held that the order of mandamus was not ambiguous and that the case could be heard by any judge presiding over the Court of First Instance of Rizal, whether it be Judge Barretto or his substitute.
Ratio Decidendi
On Issue 1: The Court held that there was no ambiguity in its previous decision or the order issued. The order was directed to Alberto Barretto as the Judge of the Court of First Instance of Rizal. While it was directed to him in his official capacity, its operation was confined to him due to the nature of the action, which concerned his qualifications to sit in a particular case. The Court reasoned that the purpose of the mandamus action was to address Judge Barretto's qualifications in relation to the pending case. If he ceased to be the judge of that province, whether permanently or temporarily, the action to compel him to proceed would become vain and useless, as such matters were beyond the Supreme Court's control. On Issue 2: The Court concluded that the action referred to in the motion is cognizable by any judge who sits as judge of the Court of First Instance of the Province of Rizal. The original order compelling Judge Barretto to proceed was based on the premise that he was qualified and should continue to preside. However, if competent authority removed or temporarily relieved him and substituted another judge, the original decree could no longer be enforced against him personally. Therefore, the case could proceed before the substitute judge, as the underlying issue was the judicial duty attached to the office, not the personal performance by a specific individual who might be removed or substituted.
Main Doctrine
The Supreme Court clarified that an order of mandamus directed to a specific judge to proceed with a trial is not rendered moot or unenforceable by the judge's temporary relief or substitution. The order is directed to the judge in his official capacity, and the action concerns his qualification to hear a particular case. Therefore, any judge presiding over the same court and handling the same case can lawfully proceed with the trial, as the original order's purpose was to compel the performance of a judicial duty attached to the office, not to a specific individual.