The Supreme Court in this case emphasized the critical importance of judicial impartiality, ruling that a judge is disqualified from handling a preliminary investigation if related to a party involved, even if that investigation is not a full trial. This ruling protects the integrity of the judicial process by preventing potential bias arising from familial connections, ensuring fair treatment for all parties from the earliest stages of a case. The Court underscored that justice must not only be done, but also be seen to be done, maintaining public confidence in the judicial system.

When Kinship Clouds Justice: Questioning a Judge’s Impartiality

The case revolves around Mayor Reynolan T. Sales, who was the defendant in a criminal case (Criminal Case No. 9448-P) before the Municipal Circuit Trial Court (MCTC) in Bangui, Ilocos Norte. The presiding judge, Melvyn U. Calvan, is the respondent in this administrative complaint. The criminal case stemmed from a shooting incident involving Mayor Sales and former Mayor Rafael Benemerito, which resulted in the latter’s death. The key issue arose because Judge Calvan’s wife is the niece of the deceased, making him related to the victim’s widow, who was the complaining witness. This familial connection led to allegations that Judge Calvan violated the Code of Judicial Conduct and the Rules of Court by taking cognizance of the preliminary investigation.

Mayor Sales argued that Judge Calvan should have disqualified himself under Rule 137, Section 1 of the Rules of Court, which prohibits a judge from sitting in any case where they are related to either party within the sixth degree of consanguinity or affinity. He also pointed to violations of the Code of Judicial Conduct, specifically Canon 2, Rule 2.03, and Canon 3, Rule 3.12, which emphasize the need for impartiality and prohibit judges from allowing family relationships to influence their judicial conduct. These rules are designed to maintain the public’s trust in the judicial system by preventing even the appearance of bias.

Judge Calvan admitted the relationship but argued that the prohibition in Rule 137, Section 1, only applies to cases where the judge makes a final judgment, not to preliminary investigations, which he described as an executive function. He cited Perez v. Suller to support his argument that issuing an arrest warrant does not constitute an irregularity even if there is a familial connection. However, the Court of Appeals later ruled that Judge Calvan’s preliminary investigation was null and void because it did not conform to constitutional, statutory, and ethical requirements. This decision underscored the importance of following proper procedure, even at the preliminary stages of a case.

The Supreme Court disagreed with Judge Calvan’s interpretation. Citing Re: Inhibition of Judge Eddie R. Rojas, the Court clarified that “to ‘sit’ in a case means ‘to hold court; to do any act of a judicial nature.’” The disqualification, therefore, applies even at the preliminary investigation stage. The Court emphasized the mandatory nature of the disqualification, stating that respondent had no option other than to inhibit himself from the criminal case. This underscores the Court’s commitment to ensuring that justice is administered fairly and impartially, without any hint of familial influence.

SECTION 1.  Disqualification of judges. — No judge or judicial officer shall sit in any case in which he, or his wife or child, is pecuniarily interested as heir, legatee, creditor or otherwise, or in which he is related to either party within the sixth degree of consanguinity or affinity, or to counsel within the fourth degree, computed according to the rules of the civil law, or in which he has been executor, administrator, guardian, trustee or counsel, or in which he has presided in any inferior court when his ruling or decision is the subject of review, without the written consent of all parties in interest, signed by them and entered upon the record. (Emphasis supplied.)

Building on this principle, the Court reinforced the need for judges to be “wholly free, disinterested, impartial, and independent” in Garcia v. De la Peña. The decision in Mayor Reynolan T. Sales v. Judge Melvyn U. Calvan underscores a judge’s obligation to maintain an unsullied image of the judiciary, worthy of the people’s trust. While the Court found no evidence to support the charge of knowingly rendering an unjust judgment or order, it held Judge Calvan liable for gross violation of the Code of Judicial Conduct and the Rules of Court.

The Court ruled that Judge Calvan should have kept abreast of legal developments, particularly Rule 112, Section 3 of the Rules of Court, which governs preliminary investigations. His failure to do so and his reliance on outdated procedures highlighted a lapse in judicial competence. For these violations, the Supreme Court found Judge Calvan guilty of gross violation of Rule 137, Section 1 of the Rules of Court, as well as Rule 2.03 of Canon 2 and Rule 3.12 of Canon 3 of the Code of Judicial Conduct. Consequently, a fine of P10,000.00 was imposed, with a warning against repeating similar offenses.

FAQs

What was the key issue in this case?	The key issue was whether a judge should be disqualified from handling a preliminary investigation if related to one of the parties involved in the case.
What rule did Judge Calvan violate?	Judge Calvan violated Rule 137, Section 1 of the Rules of Court, which prohibits a judge from sitting in a case where they are related to either party within the sixth degree of consanguinity or affinity.
Why did Mayor Sales file the complaint?	Mayor Sales filed the complaint because Judge Calvan, who was handling his criminal case, was related to the deceased victim, creating a potential conflict of interest.
What was the court’s ruling on the matter?	The court ruled that Judge Calvan was indeed disqualified from handling the preliminary investigation and found him guilty of gross violation of the Rules of Court and the Code of Judicial Conduct.
What was the penalty imposed on Judge Calvan?	A fine of P10,000.00 was imposed on Judge Calvan, along with a warning that a repetition of the same or similar offense will be dealt with more severely.
What does the term ‘sitting in a case’ mean?	According to the Court, to ‘sit’ in a case means ‘to hold court; to do any act of a judicial nature’, which includes resolving motions and issuing orders, even at the preliminary investigation stage.
What ethical guidelines were violated?	Judge Calvan violated Canon 2, Rule 2.03, and Canon 3, Rule 3.12 of the Code of Judicial Conduct, which mandate impartiality and prohibit judges from allowing family relationships to influence judicial conduct.
What was the basis of the Court of Appeals decision that was referenced?	The Court of Appeals ruled that the preliminary investigation conducted by Judge Calvan did not conform to constitutional, statutory, and ethical requirements, rendering it null and void.
Why is judicial impartiality so important?	Judicial impartiality is crucial to maintain public trust and confidence in the judicial system. It ensures fairness and objectivity in the administration of justice.

The Supreme Court’s decision reinforces the critical importance of maintaining the highest standards of judicial impartiality and competence. Judges must not only be fair but must also be perceived as fair, and must stay updated on current laws and procedures. This ruling serves as a stern reminder of the ethical responsibilities inherent in the judicial office, necessary for upholding the integrity of the justice system.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: MAYOR REYNOLAN T. SALES VS. JUDGE MELVYN U. CALVAN, G.R. No. 50383, February 27, 2002