MAYOR REYNOLAN SALES VS. JUDGE MELVYN CALVAN (February 27, 2002)




FACTS:
          Complainant is the defendant in a criminal case which arose from a shooting incident involving the latter and the former Mayor Rafael Benemerito resulting to his death. Complainant surrendered to police authorities. Respondent Judge conducted the preliminary investigation and issued an order finding probable cause for charging complainant with murder. Complainant then moved for the inhibition of the judge in taking cognizance of the criminal case on the ground that the respondent’s wife, Susana Benemerito Calvan, is the neice of the deceased. Respondent is a relative of the deceased within the third degree of affinity, and also of the wife of the deceased, who is the complaining witness in the criminal complaint.

ISSUE: Whether or not respondent Judge should inhibit himself in handling the case.

HELD: YES.
         
          The rule on compulsory disqualification of a judge to hear a case where the judge is related to either party within the sixth degree of consanguinity rests on the salutary principle that no judge should preside in a case which he is not wholly free, disinterested, impartial and independent. The appropriate step for respondent to take would have been to immediately desist from hearing the case, even at the preliminary investigation stage. His failure to do so is a glaring violation not only of the Rules of Court but also of the Code of Judicial Conduct, which mandates in Canon 3, Rule 3.12.
           
           The proceedings on preliminary investigation now consist of only one stage; Judicial competence requires that judges keep abreast of developments in law and jurisprudence, otherwise, it might result in what appears to be gross ignorance of the law.

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