G.R. Nos. L-39516-17, January 28, 1975
Rosario Castillo and Sonia Villasanta, petitioners, vs. The Honorable Judge Celestino Juan, respondent.

FACTS

Petitioners Rosario Castillo and Sonia Villasanta are the offended parties in two separate rape cases pending before respondent Judge Celestino Juan. They filed this certiorari petition seeking his disqualification on grounds of bias and prejudice, alleging a violation of the due process requirement of an impartial judge. The petitioners asserted that on two occasions in August 1974, before the prosecution had even finished presenting its evidence, respondent Judge summoned them privately to his chambers. There, he informed them of the perceived weakness of their cases, the likelihood of the accused’s acquittal, and strongly suggested they settle for monetary indemnity to avoid the embarrassment of a public trial.
Respondent Judge did not deny inviting the petitioners to confer with him. However, he defended his actions as motivated by “charity” and a desire to “humanize justice,” claiming he was acting in the petitioners’ best interests given their financial circumstances and to spare them further distress. The petitioners contended that these ex parte communications and the judge’s premature assessment of the cases’ merits demonstrated prejudgment, destroying their faith in his neutrality.

ISSUE

Whether respondent Judge should be disqualified from further hearing the rape cases due to conduct indicative of bias and prejudice, thereby violating the petitioners’ right to due process.

RULING

Yes, respondent Judge is disqualified. The Supreme Court granted the petition for certiorari, ordering him to desist from further conducting the trials. The legal logic is firmly rooted in the constitutional guarantee of due process, which mandates a hearing before an impartial and disinterested tribunal. Every litigant is entitled to “the cold neutrality of an impartial judge.” The Court found that the respondent Judge’s private conferences with the petitioners, wherein he expressed doubts about their cases and urged settlement before the evidence was fully presented, created a well-grounded suspicion of prejudgment. This conduct, regardless of his professed benevolent motives, effectively eroded the appearance of objectivity and fairness essential to judicial proceedings.
The ruling emphasizes that disqualification is warranted not only for specific statutory grounds like pecuniary interest or relationship but also for any just or valid reason that undermines impartiality, as provided under the discretionary clause of Rule 137, Section 1 of the Rules of Court. When a judge’s actions, however well-intentioned, lead parties to reasonably believe they cannot receive a fair trial, inhibition becomes necessary to preserve public confidence in the judiciary and vindicate due process. The Court clarified that this decision pertains solely to the issue of disqualification and does not touch upon the merits of the underlying criminal cases, which must be tried anew by a different judge.