GR 46117; (February, 1978) (Digest)
G.R. No. L-46117. February 22, 1978.
FRANCISCO M. BAUTISTA, petitioner, vs. HON. ALFREDO S. REBUENO, JUDGE OF THE COURT OF FIRST INSTANCE OF NAGA CITY, BRANCH IV and IRENE P. MARIANO, respondents.
FACTS
Petitioner Francisco M. Bautista seeks mandamus to compel respondent Judge Alfredo S. Rebueno to continue presiding over a civil case. The judge had issued an order disqualifying himself upon the motion of private respondent Irene P. Mariano, the plaintiff. The motion cited that the judge was a townmate and a distant relative of the plaintiff, creating a strong possibility that his actions might be suspected of partiality. Petitioner opposed, arguing the alleged reason was not among the specific mandatory grounds for disqualification enumerated in the Rules of Court.
Respondent Judge, in his order, explained his decision to inhibit. He noted from reliable sources that the defendant doubted the court’s impartiality due to the judge’s perceived relationship with the plaintiff. Conversely, the plaintiff also harbored doubts based on the defendant’s alleged boastful utterances. The judge concluded that these circumstances placed him in an untenable position where any ruling would be met with suspicion, detrimental to the court’s integrity and the people’s faith in the administration of justice.
ISSUE
Whether a judge commits grave abuse of discretion by voluntarily disqualifying himself from a case for a reason not explicitly listed among the mandatory grounds for disqualification under the Rules of Court.
RULING
The Supreme Court dismissed the petition, ruling that mandamus does not lie. The respondent Judge acted within his sound discretion and in full accordance with the law. The legal logic is anchored on the second paragraph of Rule 137 of the Rules of Court, which explicitly provides: “A judge may, in the exercise of his sound discretion, disqualify himself from sitting in a case, for just or valid reasons, other than those mentioned above.” This provision grants judges discretionary authority to inhibit themselves for valid reasons beyond the enumerated mandatory grounds, to preserve public confidence in the judiciary’s impartiality.
The Court emphasized that the preservation of trust in the judicial system is paramount. When circumstances arise that induce doubt about a judge’s probity or objectivity, even if ungrounded, the proper course is for the judge to conduct a careful self-examination. Voluntary inhibition under such conditions upholds the ideal of a coldly neutral and impartial judge, a fundamental requirement of procedural due process. The respondent Judge’s decision to inhibit, based on the perceived loss of trust from both parties which could taint the proceedings, was a valid exercise of this discretion aimed at safeguarding the integrity of the court.
The ruling is reinforced by consistent jurisprudence. In Gutierrez v. Santos, the Court sustained a judge’s voluntary inhibition where he had previously expressed an opinion on a legal issue relevant to the case, even without a lawyer-client relationship. This principle was reaffirmed in cases like Villapando v. Quitain, People v. Gomes, and Palang v. Zosa. Therefore, the respondent Judge’s order was legally sound, promoting the higher objective of maintaining an unquestionably impartial judiciary.
