GR 112684; (April, 1994) (Digest)
G.R. No. 112684 April 26, 1994
RODOLFO E. PARAYNO, CLEMARTIN B. ARBOLEDA, EDUARDO R. PEREZ, CASIMIRO C. CARANCHO, DIOSDADO T. SAMSON, MAXIMO G. SUMERA and MARCELINO M. DELA CRUZ, petitioners, vs. HON. ILUMINADO MENESES, Presiding Judge, Branch 49, Regional Trial Court, First Judicial Region, Urdaneta, Pangasinan, LORENZO M. MATEO, ARTURO ESTRADA, NORMA LUSTINA and PABLO MERCADO, respondents.
FACTS
Petitioners are the incumbent municipal mayor (Rodolfo Parayno) and members of the Sangguniang Bayan of Urdaneta, Pangasinan, who are protestees in separate election protests. The mayoralty protest (Case No. U-5346) was originally assigned to Branch 45 (Judge Manuel Villanueva), and the councilors’ protest (Case No. U-5347) to Branch 49 (respondent Judge Iluminado Meneses). After petitioner Parayno’s motion for inhibition was granted against Judge Villanueva, the case was re-raffled to Branch 49, consolidating it with the pending councilors’ protest. During the revision of ballots for the councilors’ protest on October 21, 1993, private respondent Lorenzo Mateo, a revisor for the protestants, made a manifestation on record expressing the protestants’ view that there seemed to be “a certain degree of greater sympathy of the Trial Presiding Judge to the Protestee.” The following day, respondent judge issued an order voluntarily inhibiting himself from hearing both cases. Petitioners’ motion for reconsideration was denied, prompting this petition for certiorari to set aside the inhibition orders.
ISSUE
Whether the respondent judge’s voluntary inhibition from hearing the election protest cases was based on just or valid reasons as required by law.
RULING
No. The Supreme Court granted the petition, set aside the assailed orders, and directed the respondent judge to proceed with resolving the election protests. The Court held that while a judge may, in the exercise of sound discretion, disqualify himself for just or valid reasons under Section 1, Rule 137 of the Rules of Court, the call for inhibition in this instance was bereft of legal basis and improper. The underlying reason for the rule is to ensure a judge’s impartiality, which is essential to due process. However, the voluntary inhibition must be based on good, sound, or ethical grounds, and not merely on tenuous allegations of partiality. The Court emphasized the judge’s sacred duty to administer justice without fear or favor and noted that the electoral protests had remained unresolved for a considerable time. Any further delay in their disposition, particularly given the heavy public interest involved in election protests, could not be countenanced.