G.R. No. L-41395 and L-42973 July 31, 1986
ALMARIO T. SALTA, et al. vs. COURT OF APPEALS and RENATO D. TAYAG; PATROCINIO DAYRIT vs. COURT OF APPEALS, et al.

FACTS

The consolidated petitions originated from a series of graft complaints. Almario T. Salta was initially charged by the Philippine National Bank (PNB) before the Bulacan Provincial Fiscal for violating the Anti-Graft Law (I.S. No. 3934). In turn, Salta filed a counter-complaint against Patrocinio Dayrit and Renato Tayag, among others (I.S. No. 3934-A). Both complaints were dismissed by the Provincial Fiscal. Upon reinvestigation by a District State Prosecutor, a prima facie case was found against Salta, leading to the filing of an information (CCC-V-668), while the complaint against Dayrit and Tayag was dismissed with the approval of the Department of Justice.
Subsequently, while his own criminal case (CCC-V-668) was pending trial before Judge Constante Ancheta, Salta filed a new complaint directly with Judge Ancheta against Dayrit and Tayag (CCC-V-668-A), alleging the same grounds as his previously dismissed complaint. Judge Ancheta assumed jurisdiction to conduct a preliminary investigation, suspending the trial of Salta’s own case. After investigation, Judge Ancheta found a prima facie case against Dayrit and Tayag and ordered their arrest. Dayrit and Tayag challenged this via certiorari in the Court of Appeals.

ISSUE

The core issue is whether Judge Ancheta acted with grave abuse of discretion in conducting a preliminary investigation on the complaint filed directly with him, despite the previous dismissal of an identical complaint by the fiscal and the Department of Justice, and while he was presiding over the criminal case against the complainant, Salta.

RULING

The Supreme Court ruled that Judge Ancheta committed grave abuse of discretion. The legal logic rests on the violation of judicial impartiality and the proper exercise of jurisdiction under preliminary investigation rules. While Section 13, Rule 112 of the Revised Rules of Court allowed a judge to conduct a preliminary investigation on a complaint filed directly with him if no previous investigation was conducted by a fiscal, the provision presupposes the exercise of sound judicial discretion. Here, the judge proceeded despite the prior dismissal by competent prosecutorial authorities, an act which suggested an improper motive.
Crucially, the Court emphasized that Judge Ancheta’s impartiality was irreparably compromised. He was presiding over Salta’s criminal case when he entertained Salta’s complaint against Salta’s accusers. This situation created a clear conflict of interest, fostering the perception that the judge might be induced to act with bias. A judge must maintain the “cold neutrality of an impartial judge” to satisfy due process. By refusing to inhibit himself and proceeding with the investigation, Judge Ancheta failed in this fundamental duty, thereby acting arbitrarily and capriciously. The Court, citing precedents like Pimentel v. Salanga, held that where a judge’s fairness is seriously impugned by circumstances, the proper course is to voluntarily desist from sitting on the case to preserve public confidence in the judiciary’s impartiality. Consequently, Judge Ancheta’s resolution finding a prima facie case was set aside.