Hizon v. Dela Fuente
REITERATIONFacts
1. The Antecedents: This case originated from a civil action for reconveyance of title, annulment of sale and other documents, and damages, filed by Spouses Leopoldo and Perlita Hizon against Spouses Gigi and Josephine dela Fuente and Spouses George and Adelaida Magbitang. The Hizons alleged that the sale of a land did not include the improvements thereon, specifically a three-door commercial apartment. They sought a temporary restraining order and/or writ of preliminary injunction to prevent the respondents from possessing these improvements. 2. Procedural History: During the hearing for the writ of preliminary injunction in the Regional Trial Court of Malolos, Bulacan, Branch 9, the petitioners, Spouses Hizon, filed a Motion for Voluntary Inhibition against Judge D. Roy A. Masadao, Jr., alleging bias and partiality. Judge Masadao denied this motion on August 7, 2000, and subsequently denied their motion for reconsideration on September 25, 2000. The petitioners then filed a petition for certiorari with the Court of Appeals, assailing the judge's orders for grave abuse of discretion. The Court of Appeals dismissed this petition on October 18, 2001, and denied the subsequent motion for reconsideration. 3. The Petition: The petitioners have filed a petition for review on certiorari with the Supreme Court, arguing that the Court of Appeals erred in dismissing their petition. They contend that the appellate court failed to consider that the trial judge deliberately prevented the presentation of evidence proving the commercial apartments were not included in the deed of sale. Furthermore, they claim the Court of Appeals erred in ignoring Supreme Court jurisprudence supporting inhibition and instead relying on decisions that did not contradict their cited authorities. The core issue presented to the Supreme Court is whether the trial court judge committed grave abuse of discretion in denying the motion for his inhibition.
Issue(s)
Whether the trial court judge committed grave abuse of discretion in denying the motion for his inhibition from proceeding with the civil case. Whether the alleged acts of the respondent judge during the hearing for injunctive relief demonstrated bias and partiality warranting inhibition.
Ruling
The Supreme Court resolved to DENY the petition for lack of merit.
Ratio Decidendi
On the issue of grave abuse of discretion: The Court held that the petition is devoid of merit. The rule on voluntary inhibition allows a judge to disqualify himself for just or valid reasons, but this discretion is not unfettered. Inhibition must be for just and valid reasons, and the mere imputation of bias or partiality is insufficient, especially when unsubstantiated. The Court of Appeals correctly found no basis for the petitioners' allegations. On the issue of bias and partiality: The alleged interventions by the respondent judge during the hearing for injunctive relief were within the judge's prerogatives. It is the duty of a trial judge to examine witnesses when necessary for the elucidation of the record, and asking questions for clarification purposes does not make a judge biased. The CA's finding that the judge's questions were for clarification and not to favor any party was supported by the records. The contention that the judge seemed to disregard petitioners' evidence was also dismissed, as the judge merely stressed the need for pertinent and material evidence. Mere suspicion of partiality is not enough; hard evidence of manifest bias and partiality from an extrajudicial source or other basis is required. In the absence of clear and convincing evidence, a ruling not to inhibit cannot be overturned. Disagreement with a judge's opinion does not justify imputations of unfairness without proof.
Main Doctrine
The mere imputation of bias or partiality is not enough ground for a judge to inhibit, especially when the charge is without basis. There must be hard evidence to prove it, as well as a manifest showing of bias and partiality stemming from an extrajudicial source or some other basis.