People vs. Castillo, G.R. No. 120282. April 20, 1998

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People vs. Castillo, G.R. No. 120282. April 20, 1998 prejudiced by such questioning.

udiced by such questioning. In this case, appellant failed to demonstrate


that he was prejudiced by the questions propounded by the trial judge. In
Topic: Right to Impartial Trial fact, even if all such questions and the answers thereto were eliminated,
Summary: appellant would still be convicted.

The trial court judge is not an idle arbiter during a trial. He can propound As correctly observed by the solicitor general, “there was no showing that
clarificatory questions to witnesses in order to ferret out the truth. The the judge had an interest, personal or otherwise, in the prosecution of the
impartiality of a judge cannot be assailed on the mere ground that he asked case at bar. He is therefore presumed to have acted regularly and in the
such questions during the trial. manner [that] preserve[s] the ideal of the ‘cold neutrality of an impartial
judge’ implicit in the guarantee of due process (Mateo, Jr. vs. Villaluz, 50
Facts: SCRA 18).” That the trial judge believed the evidence of the prosecution
more than that of the defense, does not indicate that he was biased. He
Robert Castillo was charged of the crime of murder (RTC). The trial court
simply accorded greater credibility to the testimony of the prosecution
gave full credence to the testimonies of the two prosecution witnesses, who
witnesses than to that of the accused.
positively identified the appellant as the killer.

Issue:

Question on Judges’ partiality in favor of the prosecution as shown by his


participation in the examination of witnesses.

Held:

No partiality in favort of prosecution. Appeal is DENIED.

The allegation of bias and prejudice is not well-taken. It is a judge’s


prerogative and duty to ask clarificatory questions to ferret out the truth.
On the whole, the Court finds that the questions propounded by the judge
were merely clarificatory in nature. Questions which merely clear up
dubious points and bring out additional relevant evidence are within judicial
prerogative. Moreover, jurisprudence teaches that allegations of bias on the
part of the trial court should be received with caution, especially when the
queries by the judge did not prejudice the accused. The propriety of a
judge’s queries is determined not necessarily by their quantity but by their
quality and, in any event, by the test of whether the defendant was

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