Title
Adapon vs. Domagtoy
Case
A.M. No. MTJ-96-1112
Decision Date
Dec 27, 1996
Judge Domagtoy issued an unauthorized release order for Bondoc, who was never arrested, violating bail requirements, demonstrating gross ignorance and abuse of authority.

Case Summary (A.M. No. MTJ-96-1112)

Background of Complaint

On May 4, 1995, warrants of arrest were issued against Pedrito Bondoc. However, the arresting officers were unable to locate him. The following day, Judge Domagtoy ordered Bondoc's release on the purported grounds that he had posted bail, despite no bailbond being filed as confirmed by the Clerk of Court on May 11, 1995. This led Adapon to file a letter-complaint to Executive Judge Melchor M. Libarnes, expressing concerns over the alleged irregularities in the approval of the bail and the subsequent order of release.

Investigation and Findings

Following the complaint, the case was forwarded for investigation. Judge Lozada, tasked with the inquiry, found no irregularities in the approval of the bailbond. He reported that on the date of the release order, a bailbond had already been filed in another court in Sta. Monica, albeit received late by the Dapa court. Ultimately, the investigation concluded that regularity in the judge's actions had not been rebutted by the complainants.

Subsequent Developments and Clarifications

On January 31, 1996, the Court directed Judge Libarnes to ascertain whether Bondoc had indeed been arrested. His findings indicated that Bondoc was never arrested, contradicting the basis on which Judge Domagtoy issued the release order. The Office of the Court Administrator (OCA) then determined that the respondent lacked authority to issue such an order as per the procedural rules outlined in the Rules of Court.

Legal Standards and Misconduct

Under Section 1 of Rule 114 of the Rules of Court, bail is defined as a security for individuals already in custody, requiring them to be arrested before any bail can be granted. The Court emphasized that granting bail under the circumstances that occurred was a violation of this rule, s

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