Castillo v. Juan Digest

Rosario Castillo & Sonia Villasanta v. Judge Celestino Juan, CFI Quezon (January 28, 1975) Huwag po, Judge Charo Facts: 1 • Petitioners were the victims in 2 separate rape cases. 5 • They assail the actuations of Judge Juan and seek his disqualification on the ground of bias and prejudice. ◦ In violation of the “cold neutrality of an impartial judge,” a requirement of due process. 6 ◦ 2 separate occasions (August 1974), in private: allegedly informed petitioners of the 2 weakness of their cases, telling them it would be to their advantage to settle. 3 ▪ Took place even before the prosecution had finished presenting its evidence. 4 • Judge Juan claimed that his acts were merely an act of charity. Issue: WON Judge Juan acted improperly and should thus be disqualified further from hearing the cases. Held: YES • In every litigation, even more in criminal cases, the manner and attitude of a trial judge are crucial to everyone concerned. • He is to refrain from reaching hasty conclusions or prejudging matters. • He must appear that he follows the traditional mode of adjudication requiring that he hear both sides with patience and understanding to keep the risk of reaching an unjust decision. • Avoid conduct that casts doubt on his impartiality. • In Mateo v. Villaluz: due process cannot be satisfied in the absence of that degree of objectivity on the part of the judge enough to reassure the litigants of his being fair and just. • Gutierrez v. Santos: cold neutrality of an impartial judge. • Thus, the Rules of Court provide for disqualification of judge other than for matters involving pecuniary interest, relationship, previous connection, etc. • The factors that lead to preferences or predilections are many and varied. • After the conferences, the offended parties could not longer be expected to have faith in his impartiality/ ◦ They could conclude that there was prejudgment. THUS: Should be disqualified.