G.R. No. L-33508 May 25, 1973
LEON UMALE, petitioner, vs. HONORABLE ONOFRE VILLALUZ, HONORABLE BENJAMIN AQUINO, PEOPLE OF THE PHILIPPINES, EDUARDO FELICIANO, ANTONIO DAVID, CECILIO CHICO, BENJAMIN ESCANDOR, ROLANDO SAMSON, and ALFONSO CO, respondents.

FACTS

Petitioner Leon Umale is the complainant in a robbery case involving his warehouse in Pasig, Rizal. The case, entitled “People vs. Marina Geronimo, et al.,” was filed directly with the Circuit Criminal Court presided by respondent Judge Onofre A. Villaluz. Judge Villaluz actively handled the case from January to April 1971, issuing various orders related to arrest, bail, and arraignment of the accused, including the private respondents.
On April 15, 1971, without any motion from the parties, Judge Villaluz voluntarily inhibited himself from trying the case. He cited his personal knowledge of the case prior to its filing as the ground, stating it was “for the peace of mind of the parties concerned and to insure an impartial administration of justice.” He ordered the records forwarded to the Executive Judge of the Court of First Instance (CFI) of Pasig for proper disposition. Petitioner’s motions for reconsideration and to return the case to the Circuit Criminal Court were denied. The case was raffled to Branch VIII of the CFI of Rizal, presided by Judge Benjamin Aquino.

ISSUE

The issues are: (1) whether a judge can voluntarily inhibit himself without a party’s motion on the ground of personal knowledge of the case acquired before its filing; and (2) whether, after acquiring jurisdiction, the Circuit Criminal Court can transfer the case to a regular Court of First Instance.

RULING

The Supreme Court dismissed the petition, upholding the validity of Judge Villaluz’s inhibition and the subsequent transfer of the case. On the first issue, the Court ruled that while personal knowledge acquired before the filing of the case is not one of the specific mandatory grounds for disqualification under the first paragraph of Section 1, Rule 137 of the Revised Rules of Court, the second paragraph of the same rule grants a judge the discretion to disqualify himself “for just or valid reason other than those mentioned” in the first paragraph. This discretionary power to inhibit is rooted in the necessity of preserving public confidence in judicial impartiality and ensuring due process. The Court cited precedents establishing that a judge may voluntarily recuse himself on grounds of bias, prejudice, or any circumstance that might reasonably cast doubt on his neutrality, as the essence of due process is the cold neutrality of an impartial judge.
On the second issue, the Court held that the transfer of the case to the regular CFI was valid. The Circuit Criminal Court and the regular CFI have concurrent jurisdiction over the robbery case under Republic Act No. 5179 . Furthermore, Section 3 of the same Act makes the laws and rules applicable to CFI judges applicable to circuit judges. Therefore, when Judge Villaluz properly inhibited himself, the procedure of raffling the case to another court within the same judicial district was permissible and analogous to standard practice when a CFI judge is disqualified. The validity of the trial depends on the court’s jurisdiction over the subject matter and the parties, and due process was observed. The Court found no abuse of discretion in the judge’s actions.