Deutsche Bank Manila v. Chua
REITERATIONFacts
The Antecedents: Deutsche Bank (Manila) filed a complaint for Sum of Money and Damages against spouses Chua Yok See and Rebecca See, Jomira Corporation, F.E.E. International Philippines, Inc., Josefina Lim, Lucita L. Kho, and Lily Co. The bank alleged that the defendants incurred a total loss of P45,812,240.00 from U.S. dollar to Philippine peso foreign exchange forward transactions due to a sudden depreciation of the peso. The bank applied the defendants' deposits in Hold-Out Accounts to cover the loss, but an unpaid amount of P11,251,032.47 remained. The defendants denied entering into these transactions and denied authorizing the bank to deal in their behalf, asserting that the contracts were unenforceable and that the bank had no cause of action against them. They counterclaimed for damages and the return of their deposits plus interest. Procedural History: The case was filed with the Regional Trial Court (RTC) of Makati, Branch 57. After trial commenced and the plaintiff presented its witnesses and documentary evidence, the defendants filed objections. On April 30, 2003, the RTC issued an order denying admission to many of the plaintiff's documentary exhibits, citing reasons such as hearsay, self-serving nature, immateriality, and irrelevance. The plaintiff moved for reconsideration and for the judge to inhibit himself, alleging bias and prejudgment. On September 5, 2003, the RTC granted the motion for reconsideration, admitting all documentary exhibits as part of the witnesses' testimonies, but denied the motion to inhibit. The plaintiff moved for partial reconsideration, seeking the judge's inhibition and the admission of exhibits for their intended purposes, which was denied on January 7, 2004. The plaintiff then filed a petition for certiorari with the Court of Appeals (CA), assailing the RTC orders. The CA dismissed the petition, finding no grave abuse of discretion on the part of the RTC judge. The Petition: Deutsche Bank Manila, as petitioner, filed a petition for review on certiorari with the Supreme Court, arguing that the Court of Appeals erred in not considering that the RTC judge committed grave abuse of discretion amounting to lack or excess of jurisdiction. Specifically, the petitioner contended that the RTC judge erred in denying admission to most of its exhibits based on perceived lack of weight rather than admissibility, and in admitting the exhibits only as part of the witnesses' testimonies. Furthermore, the petitioner argued that the RTC judge should have been compelled to inhibit himself due to bias and prejudgment, as evidenced by his rulings on the admissibility of exhibits which allegedly resolved the main factual issue of the case prematurely. The petitioner sought the reversal of the CA decision and a writ of certiorari ordering the RTC judge to inhibit himself and admitting all petitioner's documentary exhibits for the purposes for which they were offered.
Issue(s)
Whether the Court of Appeals erred in dismissing the petition for certiorari, which assailed the RTC's orders on the admissibility of documentary exhibits and the judge's alleged bias and prejudgment. Whether the RTC judge committed grave abuse of discretion amounting to lack or excess of jurisdiction in admitting the petitioner's documentary exhibits only as part of the testimonies of the witnesses. Whether the RTC judge committed grave abuse of discretion amounting to lack or excess of jurisdiction in not inhibiting himself from the case due to alleged bias and prejudgment.
Ruling
The petition is denied. The Decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the admissibility of documentary exhibits and the propriety of certiorari: The Supreme Court held that the RTC's rulings on the admissibility of evidence, even if erroneous, are errors of judgment, not errors of jurisdiction. Therefore, they are not correctible by a petition for certiorari under Rule 65. The proper remedy for the petitioner would have been to appeal the RTC's rulings on evidence after the final judgment on the merits of the case. The Court emphasized that a writ of certiorari is only for the correction of errors of jurisdiction or grave abuse of discretion amounting to lack or excess of jurisdiction, not mere errors of judgment. The fact that the documents were admitted, albeit only as part of testimonies, meant they were part of the record, and any alleged error in their admission could be raised on appeal. The Court cited Lamagan v. De la Cruz to support the principle that rulings on admissibility of evidence during trial are interlocutory and reviewable only on appeal from the final decision. On the admissibility of documentary exhibits as part of testimonies: The Court found that admitting the petitioner's documentary exhibits only as part of the testimonies of the witnesses, meant they were part of the record, and any alleged error in their admission could be raised on appeal. On the alleged bias and prejudgment of the RTC judge: The Court found no merit in the petitioner's contention that the RTC judge exhibited bias and prejudgment, necessitating his inhibition. The Court reiterated that to disqualify a judge on these grounds, the movant must prove bias and prejudice with clear and convincing evidence, typically stemming from an extrajudicial source. Mere reliance on unfavorable rulings, even if perceived as erroneous, is insufficient to establish bias. The Court noted that the RTC judge had partially reconsidered his earlier order and admitted all documentary exhibits, albeit as part of testimonies, which did not demonstrate malice or bad faith. The Court cited Webb v. People for the principle that opinions formed in the course of judicial proceedings, even if erroneous, do not prove personal bias or prejudice unless there is extrinsic evidence of malice or bad faith, or the error is so gross and patent as to produce an ineluctable inference of bad faith or malice.
Main Doctrine
A petition for certiorari under Rule 65 is not the proper remedy to assail interlocutory orders of a trial court regarding the admissibility of evidence, as such rulings are errors of judgment correctible by appeal, not errors of jurisdiction. Mere suspicion of bias or prejudice is insufficient to compel a judge's inhibition; clear and convincing evidence of bias stemming from an extrajudicial source is required.