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
Case Digest (A.M. No. RTJ-18-2523)
Facts:
The case involves an administrative complaint filed by Extra Excel International Philippines, Inc., represented by Atty. Rommel V. Oliva, against Hon. Afable E. Cajigal, the Presiding Judge of the Regional Trial Court, Branch 96, Quezon City. The complaint, dated June 6, 2018, alleges gross ignorance of the law, gross inefficiency, grave abuse of authority, and evident partiality in relation to Criminal Case No. R-QZN-13-00488-CR, where an Information for qualified theft was filed against Ike R. Katipunan, a former employee of the complainant. The case was assigned to Judge Cajigal, who, after the filing of the Information, failed to set the case for arraignment or issue a warrant of arrest. Instead, he granted the accused's motions for preliminary investigation and to defer further proceedings. The Court of Appeals later found that Judge Cajigal had committed grave abuse of discretion in granting the accused's motion for preliminary investigation.
Despite the lapse of the 60-day period for preliminary investigation, Judge Cajigal did not proceed with the arraignment, prompting the complainant to file a Motion to Set Case for Arraignment. The judge ordered the City Prosecution Office to conclude the ongoing re-investigation, which ultimately affirmed the finding of probable cause. On March 24, 2014, the complainant filed a Motion for Issuance of Hold Departure Order, which remained unresolved. The accused subsequently filed an Omnibus Motion for Judicial Determination of Probable Cause, prompting the complainant to file a Comment/Opposition and a Motion for Inhibition. The accused was eventually arraigned on June 9, 2014, but Judge Cajigal allowed him to go home despite the nonbailable nature of the offense.
On June 13, 2014, the accused filed a Petition for Bail, which Judge Cajigal found premature during the hearing on June 24, 2014, and issued a warrant...