People of the Philippines vs Court of Appeal Due Process Even the State is Entitled to It Petitioner filed a criminal case

e against Cristita Reyes, Rogen Doctora, Johny Santos, and Antonio Alegro; and another separate case against a certain Jane Go for killing her husband, Dominador, before the Tacloban RTC. The accused in those criminal cases had failed to file their complaints. As for Santos and Alegro they were already in prison when they were served notices. Petitioner complained that Judge Pedro Espina who handled these cases is not impartial as he enjoined the preliminary investigation sought to be conducted by the prosecutor against Jane Go. ISSUE: Whether or not the right to due process of the state has been violated. HELD: The SC saw it deem to decide over the case without a reply from the accused for waiting for replies would just cause further delay to the case. On of the essential requirements of procedural due process in a judicial proceeding is that there must be an impartial court or tribunal clothed with judicial power to hear and determine the matter before it. Thus, every litigant, including the State, is entitled to the cold neutrality of an impartial judge. In the case at bar, Judge Pedro Espina, as correctly pointed out by the Solicitor General, cannot be considered to adequately possess such cold neutrality of an impartial judge as to fairly assess both the evidence to be adduced by the prosecution and the defense in view of his previous decision in Special Civil Action No. 92-11-219 wherein he enjoined the preliminary investigation at the Regional State Prosecutors Office level against herein respondent Jane Go, the principal accused in the killing of her husband Dominador Go. Judge Espinas decision in favor of respondent Jane Go serves as sufficient and reasonable basis for the prosecution to seriously doubt his impartiality in handling the criminal cases. Verily, it would have been more prudent for Judge Espina to have voluntarily inhibited himself from hearing the criminal cases. CASE DIGEST ON URBANO v. IAC [157 SCRA 1 (1988)] Facts: Urbano had a dispute with Javier due to latters opening of irrigation system which flooded farmers palay storage. Urbano hacked Javier with a bolo but they had amicable settlement later on. 22 days after incident, Javier died due to tetanus. Issue: WON Urbano is criminally liable? Held: No. Civil liabilities only. Death wasnt directly due to the hacking. Proximate cause is that cause, w/c, in natural & continuous sequence, unbroken by any efficient intervening cause, produces injury & w/o w/c the result wouldnt have occurred. The rule is that the death of the victim must be the direct, natural, & logical consequence of the wound inflicted upon him by the accused to be proven beyond reasonable doubt (because this is a criminal conviction). Infection of wound was efficient intervening cause between wounding & hacking w/c was distinct & foreign to the crime. The petitioner at the very least is guilty of slight physical injury. But because Urbano & Javier used the facilities of barangay mediators to effect a compromise agreement, the criminal liability is wiped out by virtue of PD 1508, 2(3) w/c allows settlement of minor offenses.