Facts:
1. Initiation of the Case: On April 3, 1998, multiple close relatives (the private respondents) filed a complaint for specific performance and damages against the petitioners, leading to Civil Case No. CEB-21854.
2. Response of Petitioners: On May 26, 1998, the petitioners filed their answer with counterclaims and affirmative defenses.
3. Motion for Preliminary Hearing: Prior to pre-trial, the petitioners filed a motion on August 7, 1998 for a hearing on their affirmative defenses, which could be grounds for dismissal according to Section 6, Rule 16 of the 1997 Rules of Civil Procedure.
4. Denial of Hearing Motion: On August 11, 1998, the presiding judge denied the motion without hearing, ruling on the merits and dismissing several defenses including Statute of Frauds applicability and claims of full payment.
5. Petition for Certiorari: The denial was contested in a petition for certiorari before the Court of Appeals (CA) as CA-G.R. SP No. 49084, prompting the filing of a motion to suspend proceedings by the petitioners.
6. Scheduling of Pre-trial: Despite pendency, the pre-trial was set for November 9, 1998.
7. Pre-trial Postponement Request: On November 5, 1998, the petitioners requested to reset the pre-trial due to a counsel’s prior commitment, but the judge continued and ended the pre-trial.
8. Conduct of Hearings: Subsequent hearings continued with testimonies and cross-examinations despite petitioners’ plea for scheduling adjustments due to counsel availability constraints.
9. Motion for Inhibition: Filed on August 5, 1999 by petitioners seeking to inhibit the presiding judge citing bias and partiality, which was denied on August 13, 1999 due to non-appearance.
10. Appeal to the Court of Appeals: The CA ruled the apprehensions of bias were justified, ordering the judge’s inhibition, but the petitioners contested this through a Petition for Review on Certiorari to the Supreme Court.
Issues:
1. Forum Shopping Allegations: Whether respondents were guilty of forum shopping by filing multiple petitions for certiorari based on Judge Dicdican’s handling of the case.
2. Judicial Impartiality: Whether the continued participation of Judge Isaias Dicdican in the case evidenced bias or partiality justifying his inhibition.
Court’s Decision:
1. Forum Shopping: The Supreme Court found no forum shopping by respondents. The petitions filed in the CA were distinct; one concerned affirmative defenses while the other was about Judge Dicdican’s alleged partiality.
2. On Inhibition: The Supreme Court ruled that the judge need not inhibit himself. The alleged biased actions of Judge Dicdican did not meet the threshold for proven bias or partiality required for inhibition.
Doctrine:
1. Impartiality and Inhibition: Allegations of bias must be proven with concrete evidence beyond mere adverse rulings; claims based solely on judicial opinions formed within litigation proceedings and on consideration of presented evidence do not constitute ground for disqualification.
2. Forum Shopping: Differentiation between issues within multiple cases can preclude a finding of forum shopping despite similar factual backgrounds.
Class Notes:
– Compulsory vs. Voluntary Inhibition: Under R137, judges must inhibit themselves in cases involving personal interests or relations; voluntary inhibition is upon the judge’s discretion for any valid reason.
– The Sacred Oath of Judges: Judges are bound to equitable justice for all, inferred bias through rulings do not necessarily indicate misconduct.
– Forum Shopping: Defined as the practice of pursuing multiple cases to potentially benefit from different judicial outcomes, condemned in jurisprudence.
Historical Background:
The case arises from intra-family disputes over obligations under contractual agreements, reflecting prevailing legal standards and judicial expectations related to judge neutrality and due process in the Philippine judicial system near the turn of the new millennium.
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