Calayag v. Sulpicio Lines
REITERATIONFacts
The Antecedents: Petitioners, survivors of the victims of the M/V Princess of the Stars sinking, filed 71 consolidated civil damage cases against Sulpicio Lines, Inc. (now Philippine Span Asia Carrier Corporation) and its officers. Sulpicio and co-defendants filed motions for inhibition against Judge Daniel C. Villanueva, alleging bias and partiality based on specific instances: allowing testimony on actual damages without claim, admitting a photocopy of a circular despite objection and disregard for the Best Evidence Rule, admitting opinion testimony from an ordinary witness, actively participating in cross-examination and making objections for petitioners, prejudging the case by referring to Sulpicio's "notoriety," and showing hostility by calling counsel a "saling-pusa." Procedural History: Judge Villanueva denied the motions for inhibition, stating the perceived errors were out of context and meant to prevent delay. Sulpicio's motion for reconsideration was denied. Sulpicio then filed a petition for certiorari with the Court of Appeals (CA), alleging grave abuse of discretion. While the CA petition was pending, Judge Villanueva rendered a decision ordering Sulpicio and co-defendants to pay damages. Three days later, the CA granted Sulpicio's certiorari petition, ordering Judge Villanueva to recuse himself. Petitioners moved for reconsideration, which the CA denied, deeming the inhibition proceedings moot and academic due to the RTC decision. The CA also noted Sulpicio's motion to cite Judge Villanueva for contempt and its prayer for TRO/injunction, stating the inhibition order already prevented further action. The CA directed Judge Villanueva to recuse and ordered the records to be forwarded for re-raffle. The Petition: Petitioners filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the CA's decision and resolution ordering Judge Villanueva's inhibition. The Supreme Court noted a motion for intervention by other relatives of the victims. Subsequently, despite the CA's order to recuse, Judge Villanueva granted petitioners' motion for execution pending appeal. The Supreme Court issued a TRO to stay the implementation of the writ of execution pending appeal concerning actual damages.
Issue(s)
Whether the Court of Appeals erred in ordering the inhibition of Judge Villanueva from the civil cases filed against Sulpicio. Whether the CA erred in not dismissing Sulpicio's petition for certiorari for failure to attach pertinent documents. Whether the CA erred in not rendering moot and academic the motion for reconsideration despite Judge Villanueva's order granting execution pending appeal.
Ruling
The Supreme Court denied the petition, affirming the Court of Appeals' Decision and Resolution ordering Judge Villanueva's inhibition. The Court also declared Judge Villanueva's May 11, 2016 Order granting execution pending appeal NULL and VOID. The Executive Judge of the Regional Trial Court in Manila was ordered to re-raffle the consolidated cases to a new judge.
Ratio Decidendi
On the issue of inhibition: The Court found that the CA correctly ordered Judge Villanueva's inhibition. The Court noted that while mere imputation of bias is insufficient, Judge Villanueva's actions demonstrated a clear and convincing proof of bias and prejudice. Specifically, he disregarded the Best Evidence Rule by admitting a photocopy of a circular, stating it was an "authentic document" and that "[i]t does not matter." He also allowed an ordinary witness to give opinion testimony on how long a missing relative would have lived, violating the Rules on Evidence. Furthermore, his remark calling counsel a "kibitzer" or "saling-pusa" was uncalled for and publicly humiliated the counsel, displaying a state of mind of a partial judge. The Court emphasized that judges must avoid not only impropriety but also the mere appearance of impropriety to preserve public trust. On the procedural issues: The Court found no merit in the parties' mutual accusations of failing to attach pertinent documents. It noted that petitioners eventually submitted the required certified true copies of the CA decision and resolution. Regarding Sulpicio's failure to attach TSNs to its CA petition, the Court found merit in its argument that the inhibition petition quoted relevant portions of the TSNs, and a certified true copy of the motion for inhibition was appended. The Court reiterated that dismissals based on technical grounds are generally disfavored when the policy is to encourage hearings on the merits and to avoid technicalities that impede justice. On the issue of mootness and Judge Villanueva's subsequent actions: The Court found that Judge Villanueva's actions after being ordered to recuse, particularly granting the motion for execution pending appeal despite clear directives from the CA and the Executive Judge to transmit the records for re-raffle, demonstrated his "tendentious mind" and "evident predisposition." The Court held that while the pendency of a certiorari petition does not automatically stay proceedings, judicial courtesy and ethical considerations should have prompted Judge Villanueva to refrain from acting on the motion for execution pending appeal after receiving the CA's decision ordering his inhibition. His order granting execution pending appeal was thus issued with grave abuse of discretion and in excess of jurisdiction, rendering it NULL and VOID.
Main Doctrine
A judge's conduct, including remarks and rulings that demonstrate bias or disregard for procedural rules, coupled with continued action after being ordered to recuse, can constitute grave abuse of discretion warranting inhibition. The appearance of impropriety must be avoided to maintain public trust in the judiciary.