G.R. No. L-34756-59 March 31, 1973
MANUEL MATEO, JR., ROBERTO MARTINEZ alias RUBEN MARTINEZ, ENRIQUE CONCEPCION and ESMERALDO CRUZ, petitioners, vs. HON. ONOFRE VILLALUZ, as Judge of the Circuit Criminal Court, Seventh Judicial District, respondents.

FACTS

Petitioners were on trial before respondent Judge Villaluz for robbery in band with homicide. During the pendency of the case, an extrajudicial statement implicating the petitioners, executed by a later-accused individual named Rolando Reyes, was subscribed and sworn to before respondent Judge himself. Subsequently, the prosecution presented Reyes as an additional witness. On the witness stand, Reyes repudiated his prior sworn statement, claiming it was executed under threat from a government agent. Petitioners immediately moved for the disqualification of respondent Judge, arguing that his prior involvement in administering the oath to the repudiated statement placed him in a position where he could not objectively assess the credibility of Reyes’s recantation, thereby violating their right to due process.
Respondent Judge denied the motion for disqualification. He maintained that the situation did not fall under any of the specific, mandatory grounds for inhibition enumerated in the Rules of Court, such as pecuniary interest or relationship to the parties. Petitioners then filed this petition for prohibition, asserting that the judge’s refusal to recuse himself constituted a grave abuse of discretion tantamount to a denial of their constitutional right to a fair trial before an impartial tribunal.

ISSUE

Whether respondent Judge committed grave abuse of discretion in refusing to disqualify himself from the case after having previously taken the oath on the extrajudicial statement of a witness who later repudiated it before him.

RULING

Yes. The Supreme Court granted the petition for prohibition, making the restraining order permanent. The Court ruled that respondent Judge’s failure to disqualify himself constituted a grave abuse of discretion correctible by prohibition. While the factual scenario did not fit within the specific, compulsory grounds for inhibition listed in Rule 137, Section 1 of the Rules of Court, the Court emphasized that the broader constitutional guarantee of due process demands the “cold neutrality of an impartial judge.” This fundamental principle transcends the statutory enumeration.
The legal logic is clear: a judge must not only be impartial but must also appear to be impartial to maintain public confidence in the judiciary. By having officiated the sworn statement that became a central point of controversy, respondent Judge had acquired a personal knowledge of a disputed evidentiary matter. When the declarant later repudiated that very statement before the same judge, it created a situation where the judge’s objectivity in evaluating the conflicting claims—the sworn statement versus the live testimony—could reasonably be questioned. His prior participation created an impression of having prematurely accepted the statement’s validity, which could prejudice his assessment of the witness’s credibility. The Court held that under these circumstances, sound discretion dictated that the judge should have inhibited himself to preserve the sanctity of due process. The right to a fair trial before an unbiased judge is paramount, and any action that compromises the appearance of impartiality constitutes an abuse of discretion.