Facts:

In the administrative case A.M. No. MTJ-00-1320, filed on June 14, 1999, Antonio M. Bangayan, the complainant, accused Judge Jimmy R. Butacan, the Presiding Judge of the Municipal Circuit Trial Court of Solana-Enrile, Cagayan, of grave misconduct and grave abuse of discretion. The case stemmed from Bangayan’s filing of criminal charges for grave threats against Antonio Cauilan, Sr. and Antonio Cauilan, Jr., which were assigned to Judge Butacan as Criminal Case Nos. 5944 and 5945. On April 23, 1999, Judge Butacan issued warrants of arrest for both accused, setting their bail at P24,000.00 each. Antonio Cauilan, Sr. was arrested on April 29, 1999, while Antonio Cauilan, Jr. followed suit on April 30, 1999. However, both individuals were ordered released by Judge Butacan on April 30, 1999, leading to allegations of procedural irregularities. Bangayan asserted that the judge approved the release of Antonio Cauilan, Jr. without the necessary bail bond, which was only submitted on May

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Facts:

Background and Parties Involved

• Complainant: Antonio M. Bangayan, who filed an administrative complaint.
• Respondent: Judge Jimmy R. Butacan, Presiding Judge of the Municipal Circuit Trial Court of Solana-Enrile, Cagayan.
• Underlying Criminal Cases:

- Criminal Case No. 5944 and Criminal Case No. 5945 involving charges of grave threats against Antonio Cauilan, Sr. and Antonio Cauilan, Jr.

Proceedings and Arrest Warrants Issued

• On April 23, 1999, Judge Butacan allegedly issued two warrants of arrest against the accused in both Criminal Cases (5944 and 5945).
• Bail was fixed at ₱24,000.00 for each of the accused.
• Serving of Warrants:

- It is alleged that SPO1 Larry T. Urbano served both warrants on April 29, 1999, despite the respondent’s claim indicating different dates. - Certification from the warrant server reinforced the fact that both warrants were served on the same day.

Arrest, Bail Posting, and Releases

• Antonio Cauilan, Sr.

- Arrested on April 29, 1999. - Released on April 30, 1999 in Criminal Case No. 5944 after posting bail. - In Criminal Case No. 5945, despite no bail being posted, an order for his release was also issued on May 7, 1999. - Although respondent claimed that Cauilan, Jr. was not arrested, evidence and police reports indicate an arrest in April 1999. - On May 11, 1999, he filed a Motion for the Reduction of Bail. - The motion was approved by Judge Butacan, leading to his release even though the approved bail bond was submitted only after the motion was granted.

Procedural Irregularities and Alleged Violations

• Approval of Order for Release:

- For Antonio Cauilan, Sr., the release in Criminal Case No. 5945 was ordered even without the requisite posting of bail. - For Antonio Cauilan, Jr., it is contended that the release was ordered on April 30, 1999—prior to his actual arrest and before proper submission of the bond. - The motion was approved without affording the prosecution the opportunity to be heard. - The absence of a notice of hearing and failure to comply with the procedural requirements stipulated in Rule 15, A4 of the Rules of Court. - Complainant charged Judge Butacan with grave misconduct and grave abuse of discretion for allegedly allowing premature release orders and for not following due process procedures.

Recommendations by the Investigating Authorities

• The Court Administrator, Alfredo L. Benipayo, recommended that Judge Butacan be found guilty of grave misconduct.
• The recommended sanction included a fine of ₱3,000.00, accompanied by a stern warning regarding the repetition of such offenses.
• The disciplinary action was later elevated to a fine of ₱10,000.00 based on the gravity of the misconduct evidenced.

Issue:

Whether Judge Jimmy R. Butacan violated procedural rules by:

• Issuing orders for the release of the accused without the proper and timely posting of bail, particularly in Criminal Case No. 5945.
• Approving a reduction in bail for Antonio Cauilan, Jr. without first requiring the submission of the necessary bond.

• Whether the approval of the reduction of bail was done hastily and without affording the prosecution its due opportunity to be heard, in contravention of Rule 15, A4 of the Rules of Court.

• Whether the conduct of Judge Butacan constitutes grave misconduct and grave abuse of discretion, thereby warranting disciplinary sanctions under the Code of Judicial Conduct and relevant judicial ethical standards.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)