G.R. No. 148597; October 24, 2003
Grace F. Munsayac-De Villa, Lily F. Munsayac-Sunga and Roy Munsayac, petitioners, vs. Court of Appeals; Judge Antonio C. Reyes, Presiding Judge of the Regional Trial Court of Baguio City, Branch 61; Nora F. Munsayac-Visperas (Represented by Her Heirs); and Gelacio F. Munsayac Jr., respondents.

FACTS

This case originated from Special Proceedings No. 704-R, an intestate estate proceeding for the late Spouses Gelacio and Vicenta Munsayac. Petitioners Grace, Lily, and Roy, three of the five siblings, filed for letters of administration nominating Grace as administratrix. Their siblings, respondents Gelacio Jr. and Nora, opposed and nominated Gelacio Jr. The RTC, presided by Judge Antonio C. Reyes, appointed Gelacio Jr. as administrator. During proceedings, the court discovered undisclosed assets, including a substantial bank investment in the names of the late Vicenta and petitioners Grace and Lily. The RTC issued orders directing the petitioners to surrender these assets to the court’s custody.
For their failure to comply with the surrender orders, Judge Reyes issued the Orders dated June 22, 2000 and August 28, 2000, which contained directives for the arrest of the petitioners until they complied. The petitioners challenged these arrest orders via a petition for certiorari and prohibition before the Court of Appeals. Simultaneously, they had also filed a separate petition (CA-G.R. SP No. 55193) questioning other orders of Judge Reyes and an administrative case seeking his inhibition and removal.

ISSUE

The primary issue is whether the petition for the inhibition of Judge Reyes remains viable and proper.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The core legal principle applied is that a petition for the inhibition of a judge becomes moot and academic once the case before that judge has been decided with finality. The Court found that the main intestate proceedings (Special Proceedings No. 704-R) had already been terminated by a final and executory judgment. Specifically, the CA had rendered a Decision on November 29, 2001 in a related petition (CA-G.R. SP No. 64025) which had become final and was entered in the Book of Entries of Judgments on June 17, 2002.
Since the principal case over which Judge Reyes presided was already closed and terminated, any question regarding his impartiality or fitness to hear that specific case was rendered inconsequential. There was no longer any pending proceeding from which he could be inhibited. The Court emphasized that the purpose of judicial inhibition is to ensure a fair and impartial hearing; this purpose vanishes when there is no longer a live case to be heard. Therefore, the petitioners’ continued pursuit of the inhibition issue had no legal leg to stand on. The Court’s ruling underscores that courts will not rule on moot issues, as any declaration thereon would be without practical legal effect.