Case Digest (A.M. No. 92-7-360-0)
Facts:
Alicia A. Baylon v. Judge Deodoro J. Sison, A.M. No. 92-7-360-0, April 06, 1995, Supreme Court En Banc, Regalado, J., writing for the Court.The administrative complaint began with a sworn letter-request dated June 18, 1992 by Alicia A. Baylon, City Prosecutor of Dagupan City, addressed to Chief State Prosecutor Fernando P. de Leon (Department of Justice), charging Judge Deodoro J. Sison, presiding judge of Branch 40, Regional Trial Court, Dagupan City, with disregard of judicial decorum and excessive interest in handling Criminal Case No. D-10678 (People v. Manolo Salcedo, et al.). Chief State Prosecutor De Leon indorsed the letter to the Supreme Court for appropriate action.
On October 24, 1991 the Office of the City Prosecutor filed an information for double murder (Criminal Case No. D-10678), which was raffled to respondent judge. The accused filed a petition for reinvestigation on November 8, 1991; the trial court granted reinvestigation on November 20, 1991 and gave the prosecutor until December 23, 1991 to resolve it. The reinvestigation concluded on March 31, 1992, and a petition for review by the accused was dismissed by the Department of Justice on May 8, 1992.
While reinvestigation was pending, the accused filed a petition for bail on December 21, 1991 and asked that it be heard on December 23, 1991. According to the prosecutor, the petition was served December 21 (a Saturday) and set for hearing two days later; the prosecution says it had only one intervening non-working day to prepare. The trial court issued an order on December 23, 1991 granting bail (P40,000 per accused) allegedly after a hearing at which an assistant prosecutor present did not object; the order reportedly relied on the accused’s counter-affidavit(s), an affidavit of Oscar Villaga, a police blotter entry and the accused’s position paper. The prosecution filed a motion for reconsideration, denied by respondent judge on January 10, 1992.
The prosecution’s orders of December 23, 1991 (granting bail) and January 10, 1992 (denying reconsideration) were later annulled by the Court of Appeals in CA-G.R. SP No. 28384 on January 19, 1993. Meanwhile, private complainant Roberto Untalan moved for respondent’s inhibition on March 11, 1992; respondent denied the motion (March 25, 1992 (sic)), and denied the motion for reconsideration with an order of June 8, 1992 reiterating that a hearing was held and that the prosecution had failed to ask for time to show the strength of its evidence.
This administrative proceeding was referred by the Supreme Court to the Office of the Court Administrator (OCA) for evaluation on May 4, 1993. The OCA submitted its report and recommendation belatedly on February 10, 1995 after inquiries. The Supreme Court criticized the unreasonable del...(Subscriber-Only)
Issues:
- Did respondent Judge Deodoro J. Sison commit an administrative offense—gross ignorance of the law and grave abuse of discretion—by granting bail in a non‑bailable (capital) offense without affording the prosecution a proper hearing and without observance of the three‑day notice rule (Section 4, Rule 114, Rules of Court)?
- Were respondent’s defenses—that time was of the essence because the accused had been detained since October 21, 1991, and that the prosecution’s failure to object relieved him of the duty to conduct a hearing—valid legal justifications?
- What disciplinary sanc...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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