GR 163155; (July, 2006) (Digest)
G.R. No. 163155 July 21, 2006
ALFREDO HILADO, MANUEL LACSON, JOSE MA. TUVILLA, JOAQUIN LIMJAP LOPEZ SUGAR CORPORATION, petitioners, vs. JUDGE AMOR A. REYES, PRESIDING JUDGE, REGIONAL TRIAL COURT OF MANILA, BRANCH 21 and ADMINISTRATRIX JULITA CAMPOS BENEDICTO, respondents.
FACTS
Petitioners are creditors with pending collection cases against the estate of Roberto S. Benedicto. The estate proceedings were pending before the RTC of Manila, Branch 21, presided by Judge Amor A. Reyes, with the decedent’s spouse as administratrix. Petitioners’ claims were listed in the estate’s inventory of liabilities. Initially, petitioners were allowed to examine the court records. However, in December 2003, they were denied access, with the court staff instructing that only parties or those with written authority from the administratrix could inspect the records. Petitioners subsequently filed a Motion for Inhibition against Judge Reyes, alleging partiality. The judge denied this motion and related requests for document copies, ruling that petitioners, not being allowed intervenors in the estate proceedings, had no legal standing to file such pleadings or secure copies directly from the court.
ISSUE
The primary issues were: (1) Whether petitioners, as creditors listed in the inventory but not formal parties to the estate proceedings, have a right to access, examine, and obtain copies of the court records; and (2) Whether the judge committed grave abuse of discretion warranting prohibition and disqualification.
RULING
The Supreme Court partially granted the petition. On the issue of access to records, the Court ruled that court records are public documents under the constitutional right to information. This right extends to any citizen, without requiring a showing of personal interest, particularly for records of judicial proceedings. The Court emphasized that the administratrix acts as a trustee for all creditors, and petitioners’ claims were officially recognized in the inventory. Therefore, denying them access to records bearing on the estate’s assets and liabilities, which directly affect their interests, was improper. The Court ordered Judge Reyes to allow petitioners to access and copy relevant documents, subject to precautions against tampering.
However, the petition for prohibition was dismissed. The Court found no grave abuse of discretion in the judge’s refusal to inhibit herself. Under the Rules of Court, a motion for inhibition can only be filed by a party to the case. Since petitioners were not parties to the special proceedings, they lacked the legal standing to seek the judge’s disqualification, whether mandatory or voluntary. Thus, while their right to information was upheld, their procedural avenue to challenge the judge’s impartiality was not available under the circumstances.