G.R. No. A.M. No. 87-9-3918-RTC October 26, 1987
Query of Executive Judge Estrella T. Estrada, Regional Trial Court of Malolos, Bulacan, on the Conflicting Views of Regional Trial Court Judges Masadao and Elizaga Re: Criminal Case No. 4954-M

FACTS

Judge Roy A. Masadao, Jr. rendered a decision convicting Jaime Tadeo of estafa. The accused filed a motion for reconsideration. Subsequently, retired Justice J.B.L. Reyes entered his appearance for the accused. Judge Masadao then issued an order voluntarily inhibiting himself from further proceedings, citing that Justice Reyes was among those who had recommended him for appointment to the judiciary. He directed the case be transmitted to the Executive Judge for re-raffle.
The case was raffled to Branch 10, presided by Judge Luciano G. Elizaga. Judge Elizaga returned the records, refusing to act on the motion for reconsideration. He criticized the re-raffle as impractical and uncalled for, arguing that Judge Masadao should have resolved the motion himself to demonstrate his impartiality despite his relationship with the new counsel. This conflict between the two judges was certified to the Supreme Court by Executive Judge Estrada.

ISSUE

Whether Judge Masadao’s voluntary inhibition was proper, and consequently, whether Judge Elizaga is duty-bound to take cognizance of the re-raffled case.

RULING

The Supreme Court upheld Judge Masadao’s order of voluntary inhibition and ordered Judge Elizaga to take cognizance of the case. The legal logic is anchored on Rule 137, Section 1 of the Revised Rules of Court. The first paragraph enumerates specific mandatory grounds for disqualification, none of which were present here. The second paragraph provides that a judge may, in the exercise of sound discretion, disqualify himself for just or valid reasons beyond the mandatory grounds.
The Court clarified that friendship or a prior recommendatory relationship between a judge and a counsel is not a legal ground for mandatory disqualification. However, it constitutes a valid basis for voluntary inhibition if the judge perceives it could lead to a natural inclination to prejudice or cast doubt on his impartiality. The guarantee of due process requires a hearing before an impartial tribunal, and a judge has a duty to avoid any suspicion as to fairness and integrity. Judge Masadao’s subjective decision to inhibit, aimed at preserving the “cold neutrality of an impartial judge,” was a proper exercise of his discretion under the rules.
The Court found no abuse of discretion or manifest error in his order. It emphasized that judges of equal rank should be reticent in questioning a colleague’s exercise of such discretion, as internal wrangling disrupts court administration and delays case resolution. The dictates of due process, ensuring a fair and impartial tribunal, override practical concerns about case reassignment. Therefore, Judge Elizaga was ordered to assume jurisdiction over the case.