G.R. No. L-38139. May 16, 1983. TEODORO DOMANICO and CONCEPCION C. DOMANICO, petitioners, vs. COURT OF APPEALS and TRINIDAD BAMBA, respondents.
FACTS:

This case originated from a complaint for the dissolution of a partnership and accounting filed by respondent Trinidad Bamba against petitioners Teodoro Domanico and Concepcion C. Domanico. The trial court ruled in favor of Bamba, ordering the petitioners to pay her share of profits and the value of half the inventory, and to dissolve the partnership. The Court of Appeals affirmed this decision. The partnership was formed in 1952 to operate a store, with initial capital contributions from both parties. Over the years, the business relocated several times, and disputes arose regarding profit sharing and management, culminating in Bamba’s demand for liquidation in 1958, which was ignored by the petitioners.
The petitioners sought a review, primarily alleging that the trial judge’s conduct deprived them of a fair trial and due process. They cited specific instances from the transcript where the judge interjected, criticized their counsel’s questions as “incompetent,” and personally examined the petitioner Teodoro Domanico on matters like income tax payments. They argued this demonstrated bias and undue interference that obstructed their presentation of evidence.

ISSUE

Whether the trial judge’s conduct during the proceedings amounted to a denial of due process, warranting the reversal of the decision and the ordering of a new trial.

RULING

The Supreme Court denied the petition, affirming the Court of Appeals. The legal logic is that while a judge must maintain decorum and avoid undue interference that may intimidate witnesses or hinder the presentation of a case, the judge also has the prerogative and duty to intervene to clarify obscurities, prevent unnecessary waste of time, and ensure the orderly and expeditious presentation of evidence. The Court examined the cited transcript and agreed with the Court of Appeals’ finding that while the trial judge “lacked the moderation expected,” his actions did not preclude the petitioners from making an adequate presentation of their defense. The Court emphasized that the decision was not based on any immaterial matters elicited by the judge’s examination. The petitioners were given all opportunities to present their evidence, and the record did not show any error or irregularity sufficient to justify a new trial. Mere impatience or severe attitude, without a showing that it prevented the proper ascertainment of truth or presentation of the cause, does not automatically constitute a denial of due process or warrant a new trial.