Facts:

In this administrative case, Atty. Juliana Adalim-White filed a verified letter-complaint dated August 10, 2001, against Hon. Judge Arnulfo O. Bugtas, the Presiding Judge of the Regional Trial Court (RTC) Branch 2 in Borongan, Eastern Samar. The complaint arose from Judge Bugtas’s decision regarding Criminal Case No. 10772, entitled "People of the Philippines vs. Manuel Bagaporo, Jr." Judge Bugtas ordered the release of Manuel Bagaporo, Jr., who had been convicted of frustrated murder, on recognizance, despite the fact that he had not served the minimum penalty of his sentence and while his application for parole was pending. Atty. Adalim-White argued that this action displayed ignorance of the law. Following the complaint, the Office of the Court Administrator instructed Judge Bugtas to comment on the allegations, which he did on October 29, 2001, admitting that he had allowed Bagaporo's release based on certifications from prison officials. These documents suppor

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Facts:

Filing of the Complaint

• Atty. Juliana Adalim-White filed a verified letter-complaint dated August 10, 2001, before the en banc panel.
• The complaint charged Judge Arnulfo O. Bugtas, Presiding Judge of RTC, Branch 2, Borongan, Eastern Samar, with gross ignorance of the law in connection with Criminal Case No. 10772 (People vs. Manuel Bagaporo, Jr.).
• It was alleged that Judge Bugtas ordered the premature release on recognizance of Manuel Bagaporo, Jr., a convict of frustrated murder, before the convict had served the minimum portion of his imposed sentence and pending the approval of his parole application.

Respondent’s Initial Answer and Justifications

• On October 29, 2001, Judge Bugtas filed his Comment, admitting that he issued the order for release on recognizance.
• In his comment, he explained that:
• Bagaporo was convicted of frustrated murder and sentenced to imprisonment ranging from four years and two months to eight years and one day.
• The convict had already served a portion of his sentence and had filed an application for parole.
• Certifications provided by the Provincial Jail Warden and the Supervising Probation and Parole Officer supported his claim that Bagaporo was eligible for release on recognizance.
• Judge Bugtas argued that under the discretion afforded by bail rules for offenses not punishable by death, reclusion perpetua, or life imprisonment, his action was permissible.

Pre-Hearing Developments and Motions

• The Office of the Court Administrator directed Judge Bugtas to comment on the complaint, setting in motion the administrative proceedings.
• A resolution dated November 25, 2002, from the en banc panel, invited both parties to manifest whether they were willing to submit the case based solely on the pleadings.
• Despite the court’s directive, the complainant did not comply, and later, on November 16, 2004, Judge Bugtas filed a Motion to Dismiss relying on lack of evidence and the apparent desistance of the complainant.

Referral to the Court of Appeals and Subsequent Hearings

• On February 7, 2005, the en banc panel referred the case to Justice Lucas P. Bersamin of the Court of Appeals for further investigation, report, and recommendation.
• The Investigating Justice set several hearing dates:
• After the complainant’s continued failure to appear as required in prior hearings, Judge Bugtas moved to dismiss the case on procedural grounds.
• On April 29, 2005, the Investigating Justice denied the motion to dismiss and reset a final hearing for May 31, 2005, with a stern warning regarding non-appearance.
• Both parties subsequently manifested their willingness to have the case resolved on the basis of the pleadings and submissions.

Findings of the Investigating Justice

• On August 18, 2005, the Investigating Justice reported that Judge Bugtas was guilty of gross ignorance of the law and gross neglect of duty.
• Key findings included:
• Bagaporo should have been committed to a national penitentiary immediately upon conviction.
• The failure to issue the mittimus under Presidential Decree No. 29 was a serious breach of duty.
• The judge’s reliance on certificates and the mistaken application of Section 16, Rule 114 of the Rules of Court was misplaced because that provision applies only to accused persons in preventive custody and not to convicts already serving sentence.
• Judge Bugtas’s decision altered the final sentence imposed upon Bagaporo, Jr.
• The Investigating Justice recommended a fine of P25,000.00 for the act committed.

Final Determination and Penalty Imposed

• The en banc panel agreed with the findings regarding gross ignorance of the law.
• The court found that:
• The provisions of Sections 5, 16, and 24 of Rule 114 clearly preclude the release of a convict already serving his sentence.
• Judge Bugtas erroneously exercised a judicial prerogative that is reserved solely for administrative or corrective authorities, especially with regard to the release of convicts.
• Consequently, the court imposed a penalty of P40,000.00 and sternly warned that a repetition of similar conduct would be met with more severe sanctions.
• Reference was made to a previous case (Docena-Caspe vs. Bugtas) where the judge was fined P20,000.00 for analogous misconduct, thereby justifying a harsher penalty in the present instance.

Issue:

• Whether Judge Bugtas’s order releasing a convict on recognizance, even though the convict had not served the minimum portion of his indeterminate sentence, constituted gross ignorance of the law.
• Whether the application of Section 16, Rule 114, of the Rules of Court was appropriate for a convict who was already serving sentence rather than for an accused undergoing preventive custody during trial or appeal.
• Whether the subsequent administrative proceedings and the complainant’s failure to comply with procedural requirements affected the determination of the complaint.
• Whether the imposition of a fine, particularly the amount of P40,000.00, was appropriate given the judge’s earlier misconduct and the provisions of Section 11(A) of Rule 140 of the Rules of Court.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)