Title
Andres vs. Beltran
Case
A.M. No. RTJ-00-1597
Decision Date
Aug 20, 2001
Judge Beltran canceled Andres' bail without valid grounds, violating due process; fined P2,000 for grave abuse of authority.
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Case Digest (A.M. No. RTJ-00-1597)

Facts:

  1. Background of the Case:

    • Complainant Wilson Andres was charged with murder (Criminal Case No. 7155) before the Regional Trial Court (RTC) of Tuguegarao City, Branch 2.
    • The trial court, then presided by Judge Abraham Principe, granted bail to Andres, and he was released from detention.
  2. Motion to Dismiss and Denial:

    • After the prosecution presented its evidence, Andres filed a "motion to dismiss by way of demurrer to evidence."
    • Respondent Judge Orlando Beltran, acting as the presiding judge, denied the motion on November 25, 1999.
  3. Scheduled Hearing and Cancellation of Bail:

    • On November 29, 1999, the court issued a subpoena to Andres, setting the hearing for the defense's evidence on January 31, 2000.
    • During the hearing, Andres appeared, but his counsel was absent. Judge Beltran canceled Andres' bail bond and ordered his detention, citing the absence of counsel and the delay in presenting defense evidence.
  4. Detention and Release:

    • Andres was detained from January 31, 2000, to February 9, 2000, when the court ordered his release after finding that no subpoena or notice of hearing was sent to his counsel.
  5. Administrative Complaint:

    • Andres filed an administrative complaint against Judge Beltran for conduct unbecoming of a judge, serious misconduct, inefficiency, and gross ignorance of the law.
    • He argued that the cancellation of his bail bond was an abuse of authority, as the grounds cited by the judge were not provided for under the rules.
  6. Respondent Judge's Defense:

    • Judge Beltran contended that Andres was not entitled to bail as a matter of right since he was charged with murder, a capital offense.
    • He argued that he was entitled to reassess the evidence and cancel the bail if the evidence of guilt was strong.
  7. Court Administrator's Recommendation:

    • The Court Administrator recommended a fine of P2,000 for Judge Beltran for grave abuse of authority, with a stern warning against repetition.

Issue:

  1. Whether Judge Beltran's cancellation of Andres' bail bond was justified under the circumstances.
  2. Whether the absence of Andres' counsel during the scheduled hearing was a valid ground for the cancellation of bail.
  3. Whether Judge Beltran committed grave abuse of authority, serious misconduct, inefficiency, or gross ignorance of the law in handling the case.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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