G.R. No. L-52410 September 9, 1982
Floro Enterprises, Inc., petitioner, vs. Honorable Court of Appeals and Tereso Tarrosa, respondents.

FACTS

Petitioner Floro Enterprises, Inc. sought the inhibition of Judge Manuel E. Valenzuela from hearing Civil Case No. 5882-P, an action for violation of a sub-lease contract filed by Tereso Tarrosa. The judge had previously rendered a partial summary judgment against Floro, which was later set aside by the Court of Appeals as arbitrary, capricious, and whimsical. Floro argued that the judge’s findings in that summary judgment, which heavily favored Tarrosa by concluding there were no triable issues of fact despite Floro’s defenses in its answer, demonstrated bias.
Floro’s answer had raised substantial defenses, including an alleged violation of warranty by the lessor that the land was free for the lessee’s intended use, claims that government agencies refused necessary permits because the land was earmarked for airport expansion, and assertions that these issues rendered the contract void ab initio. Despite these pleadings, the judge’s summary judgment order extensively quoted the lease terms and admissions but dismissed these defenses, leading Floro to believe the judge could not be fair and objective in the subsequent trial on the merits.

ISSUE

Whether the respondent judge should voluntarily inhibit himself from hearing the remanded case on the grounds that his prior actions and the overturned partial summary judgment provide reasonable grounds for the petitioner to entertain serious doubts about his objectivity and neutrality.

RULING

The Supreme Court granted the petition and directed the judge to inhibit himself. The legal logic centers on the standards for voluntary inhibition under judicial ethics and jurisprudence. While a judge generally has a duty to try cases assigned to their sala and cannot be compelled to recuse themselves without just and valid reasons, such reasons exist when there are reasonable grounds for a litigant to entertain serious doubts about the judge’s impartiality.
The Court found such reasonable grounds present. The judge’s issuance of a partial summary judgment, later nullified by the appellate court as arbitrary, coupled with his insistence on proceeding with trial immediately even after the petitioner indicated a pending motion for reconsideration of the appellate decision, demonstrated a lack of the requisite objectivity. The Court emphasized that the test is not merely the actual rendition of a just decision but also the public perception and assurance of fairness throughout the proceedings. Given the availability of other judges to whom the case could be re-raffled with minimal inconvenience, the prudent course to dispel any appearance of bias was for the judge to voluntarily inhibit himself. The decision of the Court of Appeals was set aside.