G.R. No. 160966 October 11, 2005
Pagoda Philippines, Inc. vs. Universal Canning, Inc.

FACTS

Pagoda Philippines, Inc. filed a complaint for trademark infringement against Universal Canning, Inc. before the Regional Trial Court presided by Judge Antonio M. Eugenio, Jr. The judge initially issued a temporary restraining order against Pagoda and later dismissed Pagoda’s complaint without prejudice on the ground of insufficient verification. Pagoda filed a motion for reconsideration and subsequently filed a Motion for Voluntary Inhibition, requesting Judge Eugenio to recuse himself to ensure an impartial trial. Judge Eugenio granted the motion and issued an Order voluntarily inhibiting himself from the case.
Universal Canning filed a petition for mandamus with the Court of Appeals to compel Judge Eugenio to continue hearing the case. The CA granted the petition, set aside the inhibition order, and directed the judge to proceed. The CA ruled that the inhibition lacked a just and valid cause and that mandamus was the proper remedy due to a gross abuse of discretion. Pagoda elevated the case to the Supreme Court.

ISSUE

The principal issues were: (1) whether a petition for mandamus is the proper remedy to assail an order of voluntary inhibition; and (2) whether there was a valid and just reason for Judge Eugenio’s voluntary inhibition.

RULING

The Supreme Court denied Pagoda’s petition and affirmed the Court of Appeals. On the first issue, the Court held that while mandamus generally does not lie to control a discretionary act, it is available to correct a gross abuse of discretion, manifest injustice, or palpable excess of authority equivalent to a denial of a settled right. A judge’s decision to inhibit is not conclusive and can be reviewed via mandamus to compel judicial action when the inhibition is unjustified.
On the second issue, the Court ruled that the inhibition was not based on just and valid causes. Under Rule 137 of the Rules of Court, voluntary inhibition must be grounded on sound, objective, and compelling reasons, not a judge’s mere subjective perceptions. The mere fact that a judge had previously ruled against a party’s position, such as by dismissing a complaint, does not constitute bias or prejudice. Pagoda’s motion was based solely on its dissatisfaction with the judge’s prior adverse rulings, which is insufficient. A judge has a duty to proceed with a case unless a true ground for disqualification exists. Since no such ground was present, Judge Eugenio’s voluntary inhibition constituted a gross abuse of discretion, correctly remedied by the writ of mandamus.