G.R. No. 204014 - Philippine Stock Exchange, Inc. vs. Litonjua

Case Digest (G.R. No. 204014)
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Facts:

Background of the Complaint

On March 23, 1993, Guillerma de los Santos-Reyes filed a complaint charging Judge Camilo O. Montesa, Jr. with gross ignorance of law and evident dishonesty.
The complaint centered on the respondent judge’s decision to grant bail in Criminal Cases Nos. 487‑M‑91, 488‑M‑91, and 489‑M‑91 without a requisite petition for bail and without holding a hearing to allow the prosecution to present evidence demonstrating that the evidence of guilt was strong.

Procedural History and Prior Proceedings

The respondent judge, in his comment filed on May 24, 1993, referenced that the issue was also pending in G.R. Nos. 108478‑79 before the Second Division of the Supreme Court.
On September 22, 1993, the Supreme Court dismissed the complaint “sub judice” pending the determination of whether grave abuse of discretion was committed, reserving the right to revive the complaint should findings in G.R. Nos. 108478‑79 warrant it.
After the dismissal of G.R. Nos. 108478‑79 on February 21, 1994, the complainant moved on November 23, 1994, to revive her complaint.
On February 23, 1995, the respondent judge submitted an Additional Comment and Observation, stressing that his actions involved quashing the warrant of arrest, determining probable cause based on existing records, ordering arrests, and granting bail to accused for whom the evidence of guilt was weak.

Factual and Criminal Case Background

On November 4, 1990, an ambush along Ipo-road, Kay-pian, San Juan del Monte, Bulacan, resulted in the deaths of Patrolman Celso Reyes and Bgy. Captain Pedro Panganiban, with Armando Vitug also involved.
The National Bureau of Investigation’s inquest led to charges of murder and frustrated murder against petitioners Estelita Hipolito, Alfredo Bolsico, Romeo Adviento, Romeo Permejo, Rolando Gozum, and four John Does.
The Municipal Trial Court of San Jose del Monte, under Judge Virginia Pagarogon, conducted a preliminary investigation and issued an order on November 14, 1990, admitting the complaint and ordering the detention of all the accused based on findings of probable cause, though no bail was recommended.
Subsequent to the initial investigation and an unsatisfactory probe by the Investigating Prosecutor, the Department of Justice designated State Prosecutor Santiago Turingan to handle the cases, finding probable cause and formally charging the accused on March 13, 1991, before the Regional Trial Court of Malolos, Bulacan.

The Bail and Arrest Proceedings

On March 13, 1991, the accused filed a “Manifestation and Motion to Defer the Issuance of Warrants of Arrest” and, later, a “Petition to Grant Bail” and “Petition to Reduce Bail” despite not yet being arrested or placed under the court’s jurisdiction.
On March 25, 1991, the trial court denied the initial bail petitions because the accused had not been apprehended, noting that the court’s jurisdiction over their persons had not yet been acquired.
On April 4, 1991, the trial court consolidated the petitions for bail (after a change of heart) and set a hearing for April 6, 1991, instructing the DOJ and the Office of the Provincial Prosecutor to submit the records of the preliminary investigation within ten days.
Subsequent motions included the petitioners’ urgent motion on April 15, 1991, to quash the warrants of arrest on the grounds of want of probable cause, and on May 2, 1991, the trial court quashed these warrants and set a hearing on May 15, 1991 to determine probable cause.

Judge’s Action on Bail and Subsequent Controversies

On May 17, 1991, the trial court, after examining the records, found probable cause but converted the hearing meant to determine probable cause into a hearing on the matter of bail.
The court proceeded to grant bail to the accused without a proper petition for bail and without a hearing allowing the prosecution to show that the evidence of guilt was strong.
On August 23, 1991, the prosecution filed an omnibus motion requesting cancellation of the bail bonds and issuance of warrants of arrest, arguing that the trial court could not legally grant bail in a capital offense without allowing the prosecution to demonstrate strong evidence of guilt.
The trial court denied the prosecution’s motion on October 28, 1991, stating that its orders had become final and executory; its motion for reconsideration was subsequently denied on December 2, 1991.

Appellate and Review Proceedings

On March 3, 1992, the prosecution sought relief via certiorari, prohibition, and preliminary injunction before the Court of Appeals (CA-G.R. S.P. No. 27430) against the trial court’s bail and warrant decisions, resulting in a temporary restraining order.
Petitioners, in turn, filed a petition for certiorari, mandamus, and prohibition (CA-G.R. S.P. No. 27472) seeking annulment of new hearing dates and dismissal of the cases.
On July 31, 1992, the Court of Appeals ruled in favor of the prosecution, annulling the trial court’s questionable orders and ordering the arrest/commitment of the accused pending trial.
The petition for review (G.R. Nos. 108478‑79) filed by petitioners was dismissed on February 21, 1994.
The respondent judge later defended his action by invoking the doctrine enunciated in Lim vs. Felix, claiming that his determination of probable cause and subsequent granting of bail were proper under the law.

The Court’s Findings on Judicial Misconduct

The Supreme Court found that the trial court erroneously granted bail despite the absence of a requisite petition and without conducting a hearing that would allow the prosecution to demonstrate strong evidence of guilt.
The decision criticized the respondent judge for either gross ignorance of constitutional and statutory principles or gross incompetence that could not be excused by a claim of good faith.
The Court emphasized that bail applications should be entertained only when the defendant is already in custody or otherwise deprived of liberty, a precondition not met in the instant cases.
The judge’s conversion of a hearing for probable cause into a bail hearing was found to be a fundamental error.

Administrative Sanctions

The court recalled previous administrative matters where the respondent judge had been censured and admonished for similar misconduct and abuse of discretion.
The Court, considering the respondent judge’s repeated errors—including granting bail without due process—ordered his dismissal from service with forfeiture of all benefits and prejudice to future re-employment in any branch or service of the government.
The dismissal was to take effect immediately upon his receipt of the decision, which was to be personally served by the Office of the Court Administrator.

Issues:

Jurisdiction and Due Process

Whether the trial court had jurisdiction to grant bail to the accused who had not yet been apprehended or placed under the custody of the law.
Whether the absence of a proper bail petition and the failure to conduct a hearing for the prosecution to prove strong evidence of guilt violated due process guarantees.

Conversion of Proceedings

Whether the judge’s conversion of the hearing for the determination of probable cause (necessary for the issuance of a warrant of arrest) into a bail hearing was legally permissible.

Judicial Discretion and Legal Standards

Whether the respondent judge, by relying solely on the report and supporting documents without affording the prosecution its right to be heard, acted with gross ignorance of law or gross incompetence.
Whether the action of granting bail without following established judicial procedures reflects a disregard for the separation of functions between the executive and judicial branches in criminal proceedings.

Ruling:

(Subscriber-Only)

Ratio:

(Subscriber-Only)

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