Facts:

This case involves a verified complaint filed by Luis Balantakbo against Municipal Judge Ernesto S. Tengco of Liliw, Laguna, on January 20, 1970. The allegations centered around claims of oppression, persecution, and partiality by the respondent Judge in the performance of his judicial duties. Two criminal complaints regarding the theft of coconuts—Criminal Cases Nos. 920 and 925—were filed on the same day, with the same accused involving the Laguna Agro-Industrial Cooperative, Inc. (represented by Pio Arsenal, a client of Judge Tengco in a separate civil case). Despite these circumstances, Judge Tengco permitted the filing of two separate criminal complaints, arguably to benefit Arsenal. Furthermore, after the Judge had recused himself due to his relationship with some of the accused (namely, Amadeo Balantakbo, Luis Balantakbo, and Donato Balantakbo), he allegedly unilaterally reduced the bail for one of the accused, Romero Banay, from P2,000.00 to P1,000.00 without any formal

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Facts:

Background of the Complaint

• The verified complaint was filed by Luis Balantakbo on January 20, 1970, with the Secretary of Justice.
• The complaint charged Municipal Judge Ernesto S. Tengco of Liliw, Laguna, with oppression, persecution, and partiality in the performance of his official duties.

Specific Allegations

• Allegation on Multiple Criminal Complaints
• Despite the theft of coconuts occurring on the same day, in the same place, and involving substantially the same persons, two separate criminal complaints (Criminal Cases Nos. 920 and 925) were allowed to be filed.
• The filing of two complaints was allegedly intended to favor Pio Arsenal, President of the Laguna Agro-Industrial Cooperative, Inc., which owned the disputed properties, and who was also a client of the judge in a pending civil case.
• Allegation on Bailbond Reduction
• After the judge had inhibited himself from hearing the cases due to his personal ties with some of the accused (Amadeo Balantakbo, Luis Balantakbo, and Donato Balantakbo), Judge Pedro Urrea was designated to take over.
• Despite his inhibition and without any request (verbal or written), the respondent Judge reduced the bailbond of accused Romero Banay in Criminal Case No. 925 from P2,000.00 to P1,000.00.
• Upon receipt of P1,000.00, the accused was released.
• The reduction was alleged to have the evident purpose of gaining the good graces of Jaime Banay, the father of Romero Banay, so that the latter would testify favorably for the respondent in an administrative case.

Handling and Investigation of the Complaint

• Submission of Comment and Designation of Investigator
• The complaint was referred to the respondent Judge for comment on January 29, 1970.
• Respondent Judge submitted his comment and explanation on February 25, 1970.
• The case was referred on October 1, 1970 to the District Judge of the Court of First Instance of Laguna for investigation, report, and recommendation.
• Investigator’s Findings and Report by Judge Maximo A. Maceren
• The investigation revealed that while two complaints were filed, only Criminal Case No. 925 was accepted and proceeded with based on a preliminary examination.
• It was established and admitted that the two complaints actually pertained to the taking of coconuts from distinct parcels of land; thus, the cases did not stem from a single criminal impulse.
• Regarding the bailbond reduction, the investigator found that:
• The accused, Romero Banay, was only 12 years old, was feverish, and his immediate release was deemed necessary for humanitarian reasons.

ii. Although the action could have been performed by Judge Pedro Urrea (who was designated to hear the case), the circumstances (urgent plea from the father and the difficulty in immediately contacting Judge Urrea) justified the action. iii. There was no evidence proving improper motives.

Issue:

The Legitimacy of Filing Two Separate Complaints

• Whether the decision to allow two separate criminal complaints for the theft of coconuts—allegedly committed by the same persons and occurring on the same day—constituted abuse of judicial discretion or partiality.
• Whether the filing was intended to favor a private party (Pio Arsenal) based on his connections with the judge.

The Justification for and Legality of the Bailbond Reduction

• Whether the unilateral reduction of the bailbond from P2,000.00 to P1,000.00 was lawful and procedurally proper given the judge’s inhibition and the designated assignment to Judge Pedro Urrea.
• Whether the reduction was truly motivated by humanitarian concerns (the accused’s tender age and infirm condition) or if it was meant to curry favor with a party likely to influence an administrative case.

The Implications of the Judge’s Actions on His Official Capacity

• Whether the actions of the respondent Judge, in allowing the separate complaints and subsequently reducing the bailbond without proper procedural steps, amounted to oppression and partiality in the exercise of his official functions.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)