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.