Gutang v. Court of Appeals
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns Civil Case No. R-82-5792, wherein respondent judges issued orders pertaining to the transfer of title and possession of a property. Specifically, an order dated August 30, 1994, granted motions for the issuance of a final deed of sale, cancellation of Transfer Certificate of Title (TCT) No. 242, issuance of a new title in favor of plaintiffs Alberto Looyuko and Juan Uy, and a writ of possession over the subject property. This order was issued without prejudice to the rights of oppositors under Section 17 of Rule 39 of the Rules of Court. 2. Procedural History: Petitioner Antonia J. Gutang previously questioned the August 30, 1994 order via a Petition for Certiorari and Prohibition with TRO (CA-G.R. SP No. 35213), which was dismissed by the Court of Appeals. Subsequently, private respondents filed a motion for an alias writ of possession. On June 7, 1995, they filed a Motion to Inhibit respondent Judge Marino M. de la Cruz, Jr., citing his inaction on their motion for an alias writ. Judge de la Cruz, Jr. denied the motion for inhibition but voluntarily inhibited himself from the case on July 26, 1995, ordering the records forwarded for re-raffle. A motion for reconsideration of this inhibition order was denied. The case was then re-raffled to Branch 35, presided over by respondent Judge Ramon P. Makasiar. Petitioners then filed a petition for certiorari, prohibition, and mandamus with a prayer for a TRO before the Court of Appeals, which was dismissed on April 22, 1996. 3. The Petition: This petition for review on certiorari assails the Court of Appeals' dismissal of the petitioners' earlier petition. Petitioners argue that the Court of Appeals erred in not granting their petition for certiorari to annul the orders of inhibition and denial of reconsideration by Judge dela Cruz, Jr., as there was no legal or factual basis for the inhibition. They also contend that the Court of Appeals erred in not granting mandamus to compel Judge dela Cruz, Jr. to proceed with the case and in not granting prohibition against Judge Makasiar, thereby upholding his order granting an alias writ of possession. The core of the petition is whether Judge dela Cruz, Jr. had just and valid reasons to voluntarily inhibit himself, and whether the Court of Appeals correctly upheld this inhibition and the subsequent proceedings.
Issue(s)
Whether the Court of Appeals committed a reversible error of law in not granting the petition for certiorari to annul the orders of inhibition dated July 26, 1995 and September 5, 1995, despite finding no legal and factual basis for said inhibition. Whether the Court of Appeals committed a reversible error of law in not granting the petition for mandamus to compel Judge Marino M. dela Cruz, Jr. to proceed with the case. Whether the Court of Appeals committed a reversible error of law in not granting the petition for prohibition against Judge Ramon P. Makasiar and in annulling his order granting the alias writ of possession.
Ruling
The petition is DISMISSED. The decision of the Court of Appeals is AFFIRMED.
Ratio Decidendi
On the issue of inhibition of Judge Marino M. dela Cruz, Jr.: The Court held that while the motion for inhibition was denied, the judge voluntarily inhibited himself. This voluntary inhibition, though not based on the specific grounds enumerated in Section 1, Rule 137 of the Rules of Court, was justified under the second paragraph of the same rule, which allows inhibition for "just and valid reasons" in the exercise of sound discretion. The Court cited Pimentel v. Salanga and Intestate Estate of the Late Vito Borromeo to emphasize that a judge should conduct a careful self-examination when a suggestion of bias or prejudice is made, and should exercise discretion to preserve the people's faith in the courts. Even if the grounds for inhibition were not "legally" compelling, the judge's decision to inhibit was a prudent exercise of discretion to avoid his actions being cast under a cloud of distrust and skepticism, thereby preserving his effectiveness in dispensing justice and maintaining the impartiality of the judiciary. The Court reiterated that the decision to inhibit is primarily a matter of conscience and sound discretion, and the reviewing tribunal will not disturb it absent manifest arbitrariness or whimsicality, as trial judges are in a better position to assess the circumstances. On the issue of mandamus to compel Judge dela Cruz, Jr. to proceed: The Court ruled that mandamus would not lie to compel Judge dela Cruz, Jr. to proceed with the case because the grant or denial of a motion to inhibit involves the exercise of discretion. Since the inhibition was a valid exercise of discretion, the case was properly re-raffled. Petitioners had no vested right to the issuance of the motion to inhibit, given its discretionary nature. On the issue of enjoining Judge Ramon P. Makasiar: The Court affirmed the Court of Appeals' ruling that Judge Makasiar could not be enjoined from acting on the case. Since Judge dela Cruz, Jr.'s voluntary inhibition was deemed valid, the case was correctly re-assigned by raffle to Branch 35, presided by Judge Makasiar, in accordance with Supreme Court Circular No. 7. Therefore, Judge Makasiar could validly take cognizance of the case, and a writ of prohibition was not warranted.
Main Doctrine
A judge's voluntary inhibition, while discretionary, must be based on just and valid reasons. When circumstances suggest potential bias or impair faith in the judiciary, a judge should exercise self-examination and may inhibit to preserve impartiality, even if not legally compelled. The decision to inhibit is subjective and generally not disturbed absent manifest arbitrariness.