G.R. No. 221864. September 14, 2016.
CELERNA CALAYAG, ET AL., PETITIONERS, VS. SULPICIO LINES, INC. (NOW PHILIPPINE SPAN ASIA CARRIER CORPORATION), RESPONDENT.

FACTS

Petitioners are survivors and relatives of victims of the M/V Princess of the Stars maritime disaster. They filed seventy-one consolidated civil cases for damages against respondent Sulpicio Lines, Inc. before the Regional Trial Court (RTC) of Manila, Branch 49, presided by Judge Daniel C. Villanueva. During trial, Sulpicio filed a motion for Judge Villanueva’s inhibition, alleging manifest partiality and bias. The grounds included allowing opinion testimony from an ordinary witness, admitting a mere photocopy of a document over a best evidence rule objection, actively participating in cross-examination to aid petitioners, and making prejudicial remarks about Sulpicio’s “notoriety” and referring to its counsel as a “saling-pusa” (kibitzer).
Judge Villanueva denied the motion, stating his rulings were to prevent delay and that the remarks were taken out of context. Sulpicio filed a petition for certiorari with the Court of Appeals (CA) to challenge this denial. While the CA petition was pending, Judge Villanueva proceeded to render a decision on the merits in favor of petitioners. Three days later, the CA granted Sulpicio’s petition, ordering Judge Villanueva to recuse himself. Petitioners moved for reconsideration, but the CA denied it, declaring the inhibition issue moot and academic due to the already-promulgated RTC decision.

ISSUE

Whether the Court of Appeals erred in granting the petition for certiorari and ordering Judge Villanueva’s inhibition after he had already decided the main case on the merits.

RULING

The Supreme Court granted the petition and reversed the CA. The core legal logic is that the CA’s directive for inhibition became functus officio—it had lost its practical purpose and legal force. When Judge Villanueva decided the consolidated civil cases, he completed his judicial function in those matters. An order for his recusal, issued thereafter, could no longer be executed as there was nothing left for him to inhibit from. The CA itself recognized this by declaring the issue moot and academic in its subsequent resolution.
The Supreme Court clarified that the proper remedy for any perceived bias or legal errors committed by the trial judge was to raise them as issues in a regular appeal of the main decision on the merits. Sulpicio had already filed a notice of appeal, making that the correct procedural avenue. The Court emphasized that certiorari is not a substitute for appeal. Any alleged grave abuse of discretion in the trial court’s conduct could be thoroughly reviewed by the appellate court examining the entire record of the concluded case. Therefore, the CA’s decision, though correctly identifying mootness later, initially erred by issuing a dispositive portion (the inhibition order) that was already ineffectual and could not be enforced, creating an inconsistency within its own rulings. The case was remanded to the CA for proper consolidation and resolution of the appealed main case.