Case Digest (A.M. No. MTJ-00-1321)
Facts:
Victory Liner, Inc. v. Judge Reynaldo B. Bellosillo, A.M. No. MTJ-00-1321, March 10, 2004, the Supreme Court First Division, Davide Jr., J., writing for the Court.The complainant was Victory Liner, Inc. (VLI), represented by its president Johnny T. Hernandez; the respondent was Judge Reynaldo B. Bellosillo, then Presiding Judge of the Municipal Circuit Trial Court (MCTC) of Orani and Acting Presiding Judge of the MCTC of Dinalupihan-Hermosa, Bataan. VLI filed a verified administrative complaint with the Office of the Court Administrator (OCA) accusing Judge Bellosillo of gross ignorance of the law, grave abuse of authority, oppression, and inaction on a pending motion arising from a vehicular accident.
On March 2, 2000, a VLI bus (Plate No. CWF-935) struck Marciana Bautista Morales, who died the next day. VLI paid funeral expenses and on March 6, 2000, entered into an Agreement/Undertaking with the heirs; on March 14, 2000, a designated representative executed a Release of Claim and an Affidavit of Desistance. Separately, on March 3, 2000, two of the victim’s sons executed a Pinagsamang Salaysay against the driver Reino de la Cruz; this led to a criminal complaint docketed as Criminal Case No. 10512.
After preliminary examination, on March 13, 2000, Judge Bellosillo issued a warrant for De la Cruz’s arrest, fixed bail at P50,000 to be posted in cash, and ordered the police to impound the bus and release it only upon posting a cash bond of P50,000. On March 30, 2000, VLI deposited P50,000 under protest for the bus’s release; the bus was released, but on April 4, 2000 Judge Bellosillo ordered re-impoundment and asked police to explain why they released the bus without a court order. On April 18, 2000 he acted on VLI’s Manifestation and Motion and ordered the bus released.
VLI filed a petition in Judge Bellosillo’s court on April 4, 2000 to declare null and void the order requiring the bond; the petition was dismissed for improper venue and lack of jurisdiction because VLI’s counsel allegedly failed to appear on the hearing date. On June 23, 2000, VLI filed the verified complaint with the OCA alleging, among other things, that Judge Bellosillo (a) grossly ignored the law by impounding the bus and requiring a cash bond; (b) gravely abused authority by revoking a surety bond in an unrelated case and increasing bail to P350,000; (c) ordered police to file charges against De la Cruz; and (d) was derelict in failing to resolve VLI’s petition.
In his comment, Judge Bellosillo defended his actions as discretionary and in the interest of justice, explained the rationale for requiring cash bonds (subsidiary liability, expired/insufficient sureties, prosecutor’s request, accused’s fugitive status), and blamed VLI’s counsel for misleading the police and failing to appear. OCA Consultant (retired Justice) Narciso T. Atienza recommended a finding of error in the impounding and in requiring a P50,000 cash bond, and that the respondent had fixed excessive bail amounts; he recommended a P20,000 fine but exonerated the judge of compelling the police to file the complaint and found that the petition to nullify had been resolved on April 10, 2000.
Judge Bellosillo had resigned effective March 27, 2002; the Court nevertheless accepted jurisdiction over the administrative complaint, citing precedent that resignation does not render such proceedings moot. After review, the Court agreed with OCA in exonerating the respondent on the charge of compelling the police to file charges and on inaction, but declined to decide in the administrative case on the broader question whether trial judges may lawfully require bus operators to post bail for impounded vehicles—holding that that issue should have been litigated in the proper courts. The Court found, however, that Judge Bellosillo committed gross ignorance of the law and oppression by imposing excessive cash bail on accused Reino de la Cruz (Crim. Case No. 10512) and on Edwin Serrano (Crim. Case No. 9373), and ordered a fine of P10,000 to be taken from his retirement benefits. Ynares‑Santiago, Carpio, and Azcuna, JJ., concurred; Panganiban, J., was on official leave.
Issues:
- Does the resignation of Judge Bellosillo render the administrative complaint moot and deprive the Court of jurisdiction to proceed?
- Is an administrative complaint the proper forum to determine the legality of a trial court’s order impounding a vehicle and requiring a bus owner to post a cash bond for its release?
- Did Judge Bellosillo commit gross ignorance of the law or grave abuse of authority by impounding VLI’s bus and requiring a P50,000 cash bond for its release?
- Did Judge Bellosillo commit gross ignorance of the law, oppression, or other administrative offense by fixing excessive cash bail (and converting surety bonds to cash) for accused Reino de la Cruz and Edwin Serrano?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)