Title
Extra Excel International Philippines, Inc. vs. Cajigal
Case
A.M. No. RTJ-18-2523
Decision Date
Jun 6, 2018
Judge Afable E. Cajigal was penalized with a P20,000 fine from his retirement benefits for gross inefficiency and ignorance of the law in a qualified theft case.
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Case Digest (A.M. No. RTJ-18-2523)

Facts:

  • Extra Excel International Philippines, Inc. filed an administrative complaint against Hon. Afable E. Cajigal, Presiding Judge of the Regional Trial Court, Branch 96, Quezon City.
  • The complaint, dated June 6, 2018, alleged gross ignorance of the law, gross inefficiency, grave abuse of authority, and evident partiality related to Criminal Case No. R-QZN-13-00488-CR.
  • The case involved Ike R. Katipunan, a former employee accused of qualified theft.
  • Judge Cajigal failed to set the case for arraignment or issue a warrant of arrest after the Information was filed.
  • He granted the accused's motions for preliminary investigation and deferred further proceedings.
  • The Court of Appeals later found Judge Cajigal had committed grave abuse of discretion.
  • Despite the 60-day period for preliminary investigation lapsing, he did not proceed with the arraignment.
  • The complainant filed a Motion to Set Case for Arraignment, which led to a re-investigation affirming probable cause.
  • A Motion for Issuance of Hold Departure Order filed by the complainant remained unresolved.
  • The accused filed an Omnibus Motion for Judicial Determination of Probable Cause, leading to further motions from the complainant.
  • The accused was arraigned on June 9, 2014, but was allowed to leave despite the offense being nonbailable.
  • Judge Cajigal found the accused's Petition for Bail premature but later granted it without a proper hearing.
  • The complainant argued that these actions showed gross inefficiency and evident partiality.
  • Judge Cajigal defended himself, claiming the allegations were unfounded and that Atty. Oliva lacked standing to file the complaint.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court found Judge Cajigal administratively liable for gross ignorance of the law and gross inefficiency.
  • He was ordered to pay a fine ...(Unlock)

Ratio:

  • The Court determined that Judge Cajigal's failure to resolve the motion for a hold departure order within the required 90-day period constituted gross inefficiency.
  • Judges must dispose of cases and motions promptly to uphold public confidence in the judiciary.
  • Allowing the accused to go home post-arraignment, despite the nonbailable nature of the offense, indicated gross ignorance of the law.
  • A proper judicial determination of probable cause is...continue reading

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