Parayno v. Meneses
REITERATIONFacts
The Antecedents: Petitioners Rodolfo E. Parayno (municipal mayor) and members of the Sangguniang Bayan of Urdaneta, Pangasinan, were protestees in separate election protests pending before the Regional Trial Court (RTC) of Urdaneta, Pangasinan. The mayoralty protest was initially assigned to Branch 45, presided over by Judge Manuel Villanueva, while the councilors' protest was assigned to Branch 49, presided over by respondent Judge Iluminado Meneses. Procedural History: Petitioner Parayno filed a motion for inhibition against Judge Villanueva, which was granted. The case was then assigned to Branch 46, but this assignment was assailed before the Supreme Court, which remanded the case to the Court of Appeals. The appellate court ordered the case to be included in the regular raffle, leading to its re-assignment to Branch 49, where the councilors' protest was pending. The Petition: On October 21, 1993, during the revision of ballots for the councilors' protest, private respondent Lorenzo Mateo manifested that the presiding judge of Branch 49 was the same judge for the mayoralty protest, suggesting a degree of sympathy towards the protestee. The following day, respondent Judge Meneses issued an order inhibiting himself from hearing both cases. Petitioners sought reconsideration, which was denied. This petition for certiorari seeks to set aside the inhibition order and the denial of the motion for reconsideration.
Issue(s)
Whether respondent Judge Iluminado Meneses committed grave abuse of discretion in voluntarily inhibiting himself from hearing the election protests based on a party's manifestation of perceived sympathy.
Ruling
The petition is granted. The assailed Orders of the respondent Judge inhibiting himself from hearing the election protests are set aside, and he is directed to proceed with dispatch in resolving the cases.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the voluntary inhibition was improper. Under Rule 137, Section 1 of the Rules of Court, while a judge may exercise discretion to disqualify himself for reasons other than mandatory grounds, such discretion must be based on sound or ethical grounds. The Court emphasized that a litigant is entitled to the 'cold neutrality' of a judge as a requirement of due process, but this does not permit a judge to shirk their 'sacred duty to administer justice without fear or favor' based on 'tenuous allegations of partiality.' Applying the principles from Castillo v. Juan (62 SCRA 124) and Fernandez v. Presbitero (79 SCRA 61), the Court noted that impartiality is a state of mind that requires more than a mere manifestation of doubt by a party to be legally questioned. Furthermore, the Court highlighted that election protests are imbued with public interest, and unnecessary delays in their disposition—such as those caused by groundless inhibitions—cannot be countenanced. Therefore, the respondent Judge's decision to inhibit himself lacked a valid legal basis under the circumstances.
Main Doctrine
A judge's voluntary inhibition from a case, while permissible in the exercise of sound discretion for just or valid reasons, must be based on good, sound, or ethical grounds, and not on tenuous allegations of partiality, especially when such inhibition would cause further delay in the resolution of cases involving public interest, such as election protests.