Facts:

• Guillerma D. CabaAero filed a complaint against Judge Antonio K. CaAon of the Municipal Circuit Trial Court of Hinatuan-Tagbina on September 16, 1999.
• The complaint alleged partiality, unjust interlocutory orders, and grave abuse of discretion in Criminal Case No. 4036-H (People vs. Jessie CabaAero).
• Jessie D. CabaAero, Guillerma's son, was accused of unlawfully harvesting falcata trees valued at P3,191.00 from Jaime CaAal's farmland.
• During the preliminary investigation, Guillerma claimed Judge CaAon asked leading questions that implicated her as a co-accused.
• On October 1, 1998, Judge CaAon issued a warrant of arrest for both Jessie and Guillerma, alleging Guillerma was covering for her son.
• Guillerma was arrested on October 15, 1998, and detained; she later posted bail, which was initially problematic as she was not formally accused.
• The judge set the bail at P30,000, which Guillerma argued was excessive given the value of the alleged stolen property.
• Judge CaAon justified the arrest and bail by claiming Guillerma was a principal by inducement.
• Judge CaAon passed away on April 24, 2000, before the administrative complaint was resolved, but the court maintained the complaint was still valid.

Issue:

• (Unlock)

Ruling:

• The court ruled that the death of Judge Antonio K. CaAon does not warrant the dismissal of the administrative complaint.
• The court found insufficient evidence to support the charge of partiality against Judge CaAon.
• The court ruled that Judge CaAon committed gr...(Unlock)

Ratio:

• The court emphasized that a judge's death does not automatically lead to the dismissal of an administrative complaint filed while he was in service, as established in prior jurisprudence.
• For the charge of partiality, the court outlined that adequate evidence is necessary, and bias must arise from an extrajudicial source.
• The court found no substantial evidence supporting the allegations of bias against Judge CaAon.
• However, the court dete...continue reading