Title: 001 MUNSAYAC-DE VILLA v.

COURT OF APPEALS
Citation: 414 SCRA 436
Prepared by: Alarios, Patricia Anne

Facts:
In a special proceeding case for letters of administration of the late Munsayac couple’s
estate, Gelacio Munsayac, Jr. was appointed as administrator. Gelacio’s other siblings thereafter
requested for the Judge’s inhibition from the case and assailed the arrest order issued against
them which required the immediate surrender of certain amounts of money to the RTC. The CA
nullified the arrest order based on the finding that it was issued without any written charge or
hearing. With respect to the petition for inhibition, the CA found no convincing proof of the
Judge’s allegedly suspicious demeanor. Gelacio’s siblings then appealed to the Supreme Court,
arguing that the CA should have ordered the inhibition of the Judge due to his alleged
vindictiveness, arbitrariness, and prejudice against them. They claim that inhibition is still
necessary because there are still other matters pending before the trial court, such as the
withdrawal of money in custodia legis.

Issue:
Whether the Petition for Inhibition should be granted — NO

Decision of the Court:

The main case from which the Petition for Inhibition arose has already been decided with
finality by the CA. This main case refers to the Special Proceeding which had given rise to a
number of incidents and petitions, including the subject Petition for Inhibition. Since the CA has
already terminated the main case, there is no more reason for the trial court Judge to inhibit from
a case that has been decided with finality. In this case, the only matters left to be done is to lift
the to order the release of any property in custodia legis. Thus, to expedite the case and in the
interest of substantial justice, the SC directed the trial court Judge to do so.

Once a case has been decided with finality, a petition for the inhibition of the Judge
therefrom becomes moot and academic.