Ty v. Banco Filipino Savings and Mortgage Bank
REITERATIONFacts
The Antecedents: Respondent Banco Filipino Savings and Mortgage Bank (Banco Filipino) filed an action for reconveyance of real property against petitioner Nancy Ty and others (Tala, et al.). The trial court initially dismissed the complaint for lack of jurisdiction but reinstated it upon motion for reconsideration. Tala, et al. (except Nancy Ty and Cynthia Mesina) filed a motion for reconsideration which was denied. Subsequently, Tala, et al. filed a motion to suspend proceedings pending appeal, which was also denied. Banco Filipino moved for the production of documents, which the trial court granted despite Tala, et al.'s opposition and without Banco Filipino advancing costs, citing that for documents required by law to be kept, production costs cannot be assessed against the movant. The trial court later declared certain facts as established and struck out defenses in Tala, et al.'s Answer, prohibiting them from presenting contrary evidence. Tala, et al. failed to produce requested documents, leading to a Supplemental Order for production. The trial court admitted all exhibits offered by Banco Filipino despite pending replies and rejoinders. Tala, et al. then filed a motion for inhibition and/or disqualification of the respondent judge on grounds of manifest prejudgment and partiality. Procedural History: The respondent judge denied the motion for inhibition, stating his orders were based on facts and law, and reprimanded Tala, et al. for filing dilatory motions. Separate motions for reconsideration by Nancy Ty and Tala, et al. were denied. Nancy Ty and Tala, et al. filed separate petitions for certiorari and prohibition with the Court of Appeals, assailing the denial orders. The Court of Appeals dismissed these petitions, affirming the trial court's orders. The Petition: Petitioner Nancy Ty filed a petition for review on certiorari, seeking to set aside the Court of Appeals' decision, arguing that the appellate court erred in affirming the trial court's denial of the motion for inhibition, alleging manifest bias and partiality of the respondent judge.
Issue(s)
Whether the Court of Appeals erred in affirming the denial of the motion for inhibition filed by the petitioner. Whether the respondent judge committed grave abuse of discretion in denying the motion for voluntary inhibition.
Ruling
The petition is GRANTED. The June 7, 2001 Decision of the Court of Appeals is REVERSED and SET ASIDE. The respondent judge is directed to inhibit himself from presiding in Civil Case No. 4521, and the Executive Judge of the Regional Trial Court of Batangas City is directed to re-raffle the said case to another judge.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in affirming the denial of the motion for inhibition: The Supreme Court granted the petition, reversing the Court of Appeals' decision. The Court found that the consistency and regularity with which the respondent judge issued directives gave rise to clear and convincing proof of bias and prejudice, not merely a fanciful suggestion or superficial impression. The Court emphasized that while bias or prejudice must typically stem from an extra-judicial or extrinsic source, this rule does not apply when a judge displays an inordinate predisposition to deviate from established procedural precepts, demonstrating obvious partiality. On the issue of grave abuse of discretion in denying the motion for voluntary inhibition: The Court noted that while erroneous issuance of orders may not always be grounds for bias, when these orders, taken collectively, ineluctably show that the judge has lost the cold neutrality of an impartial magistrate, due process dictates voluntary inhibition. The Court cited the case of Bautista v. Rebueno, stating that at the first sign of lack of faith and trust, a judge should conduct a careful self-examination and, if circumstances induce doubt as to his actuations, the better course is to disqualify himself to preserve people's faith in the judiciary. The Court found that the respondent judge's actions, such as presuming the receipt of pleadings without proper proof of service, justifying non-payment of production costs with unsubstantiated claims of insignificance, ordering the presentation of specific evidence without a motion, and resolving the offer of exhibits hastily, collectively demonstrated bias and prejudice, warranting inhibition. The Court concluded that the Court of Appeals erred in affirming the denial of the motion for inhibition.
Main Doctrine
A judge must inhibit himself from a case if circumstances appear that would induce doubt as to his honest actuations and probity in favor of either party, even if not legally prohibited from sitting in the litigation, to preserve the people's faith in the courts.