### Facts:
This case began with Atty. Romulo B. Macalintal’s letter dated April 1, 1996, to the Philippine Supreme Court, detailing the actions of Judge Angelito C. Teh in Election Case No. R-95-001. Macalintal’s client had received an adverse resolution from Judge Teh. Macalintal filed a petition for certiorari with the Commission on Elections (COMELEC) while the case was still pending. Judge Teh actively participated in the COMELEC proceedings by filing a comment and an urgent manifestation. Macalintal then filed a motion to inhibit Judge Teh from further action in the election case, but instead of deciding on the motion, Judge Teh hired a lawyer and submitted an answer in his own court, demanding the motion’s dismissal and attorney’s fees from Macalintal.
Upon review, the Supreme Court took Macalintal’s letter as an administrative complaint and directed Judge Teh to manage the motion for inhibition as outlined in the Rules of Court and to submit comments on the complaint. Teh and Macalintal expressed readiness to resolve the case based on the pleadings. The Supreme Court noted Judge Teh’s admissions and proceeded with the case despite Macalintal’s letter not being under oath, applying the doctrine of res ipsa loquitur due to the clear impropriety in Judge Teh’s actions.
### Issues:
1. Whether Judge Teh’s personal participation in the certiorari proceedings was appropriate.
2. Whether Judge Teh improperly acted on the motion for inhibition by hiring a lawyer and filing an answer, rather than following the prescribed judicial procedures.
3. Whether Judge Teh’s actions violated the judicial norms of independence, competence, and integrity.
### Court’s Decision:
The Philippine Supreme Court decisively found Judge Angelito C. Teh guilty of gross ignorance of the law. The Court ruled that Judge Teh inappropriately involved himself in the certiorari process despite being only a nominal party, thereby deviating from established judicial expectations which dictate a judge’s non-involvement in such proceedings. Furthermore, Judge Teh’s handling of the motion for inhibition, particularly his self-representation and submission of an answer within his court, was deemed a serious misstep. Teh’s resolution to deny the motion for inhibition and impose attorney’s fees on Macalintal was criticized for lacking a sufficient legal basis and for demonstrating gross incompetence. Consequently, Judge Teh was dismissed from service, with a forfeiture of all benefits and a prohibition against government re-employment.
### Doctrine:
The case reiterated the principle that judges must maintain impartiality and desist from active participation in proceedings that challenge their own orders or decisions. Moreover, it emphasized that adherence to procedures prescribed for judicial conduct, especially regarding motions for inhibition, is paramount for ensuring fairness and the integrity of the judiciary. This upholds the doctrine that a judge must not act as both a litigant and a judge in their own court.
### Class Notes:
– **Key Concepts:** Judicial Impartiality, Motion for Inhibition, Gross Ignorance of the Law.
– **Rule 65, Section 5 of the Rules of Court:** Specifies that judges do not have to actively participate in appellate proceedings challenging their orders.
– **Section 2, Rule 137 of the Rules of Court:** Outlines the procedure for a judge to follow upon receiving a motion for inhibition, emphasizing the judge’s commitment to impartiality and procedural propriety.
– **Res Ipsa Loquitur:** The principle that allows the facts of a case to speak for themselves, applied here due to the clear misconduct of the judge in question.
### Historical Background:
This case emphasizes the Philippine judiciary’s commitment to maintaining judicial integrity and competence, demonstrating the mechanisms in place for addressing misconduct within the judiciary. It highlights the judiciary’s self-regulatory processes and reflects on the broader context of legal professionalism and accountability in the Philippines.
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