G.R. No. L-47737 May 27, 1981
Haniel R. Castro, petitioner, vs. Honorable Juan Y. Reyes, in his capacity as Presiding Judge of the Court of First Instance of Cebu, Branch I, Cebu City, and San Miguel Corporation, respondents.

FACTS

Petitioner Haniel R. Castro is a defendant in a civil case for recovery of a sum of money and damages filed by San Miguel Corporation before respondent Judge Juan Y. Reyes. Castro filed an ex-parte motion for re-raffle of the civil case, citing a prior criminal case for estafa where the same respondent Judge had voluntarily inhibited himself upon Castro’s motion. The petitioner argued that due to this prior incident, he honestly felt it would be in the best interest of justice for the civil case to be reassigned.
Respondent Judge denied the motion for re-raffle, finding it without merit. A motion for reconsideration was likewise denied, with the petitioner expressing fear that the judge would not be impartial. Castro then filed this petition for prohibition, contending that the judge’s prior voluntary inhibition in the criminal case justified his disqualification in the present civil case to preserve the appearance of impartiality.

ISSUE

Whether respondent Judge committed grave abuse of discretion warranting prohibition by denying the motion for re-raffle and refusing to voluntarily inhibit himself from the civil case.

RULING

The Supreme Court dismissed the petition. The legal logic centers on the principle that while voluntary inhibition is encouraged to preserve the “cold neutrality of an impartial judge,” it is not automatically required simply because a judge previously disqualified himself in a different case involving the same party. The factual circumstances of each case must be carefully examined to determine if a valid reason for inhibition exists.
In the prior criminal case, the respondent Judge’s voluntary inhibition was based on his expression of a legal view on the doctrine of estafa, which could plausibly be interpreted by the accused as prejudicial. This constituted a just and valid reason for disqualification under the sound discretion of the judge. In contrast, the present civil case involves a completely different cause of action—recovery of money and damages arising from the sinking of a carrier—with no showing of any bias, prejudice, or similar circumstance from the judge. The mere identity of the party, without any factual basis indicating partiality or abuse in the civil proceedings, is insufficient to compel inhibition. The Court found the petitioner’s fear to be more imaginary than real and held that the respondent Judge did not commit grave abuse of discretion in denying the motion.