G.R. No. 185484 June 27, 2018
FRANCISCO I. CHAVEZ, PETITIONER, VS. IMELDA R. MARCOS, RESPONDENT.

FACTS

This case involves a Petition for Review on Certiorari assailing the Court of Appeals’ dismissal of Francisco Chavez’s Petition for Certiorari, which sought to reverse the Regional Trial Court’s denial of a motion for inhibition. The underlying consolidated criminal cases were filed against Imelda R. Marcos for violations of the Central Bank Act, alleging she and her late husband maintained foreign exchange accounts abroad without authorization and failed to report foreign exchange earnings.
The prosecution filed a motion for the trial judge to inhibit himself, alleging bias and partiality. The motion cited the judge’s conduct during hearings, including his alleged hostile and sarcastic interjections towards the prosecution, his active assistance to the defense in objecting to evidence, and his issuance of orders that purportedly favored the defense by restricting the prosecution’s presentation of its case. The trial judge denied the motion, and this denial was affirmed by the Court of Appeals.

ISSUE

Whether the Court of Appeals erred in affirming the trial judge’s denial of the motion for inhibition, thereby upholding the judge’s continued handling of the criminal cases against Imelda Marcos.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals’ ruling. The Court held that the motion for inhibition was correctly denied as the allegations of bias and partiality were not substantiated by clear and convincing evidence. The presumption that a judge will dispense justice impartially must prevail unless overcome by such evidence.
The Court meticulously reviewed the cited instances of alleged bias, such as the judge’s interjections and procedural rulings. It found that the judge’s actions were within the scope of his judicial discretion to control the proceedings, clarify matters, and ensure an orderly trial. His interjections, even if pointed, were aimed at expediting the trial and were not demonstrative of a pre-judgment of the case’s merits. The procedural orders limiting the prosecution’s presentation were based on the judge’s assessment of the rules of evidence and procedure, not on partiality. The Court emphasized that a judge’s adverse rulings, by themselves, are not sufficient grounds for inhibition. The prosecution failed to prove that the judge had a personal, substantial, and pecuniary interest in the case, or that he exhibited such a deep-seated antagonism as to make a fair judgment impossible. Therefore, no grave abuse of discretion attended the trial judge’s refusal to inhibit himself.