Case Summary (A.M. No. RTJ-04-1845)
Background of the Case
The case arose when Judge Gregorio R. Balanag, Jr. of the Municipal Circuit Trial Court of Kiamba-Maitum issued a warrant of arrest for Faustino Ancheta on March 18, 2003, regarding a murder charge but did not recommend bail. Following his arrest warrant, there was a delay in Ancheta’s arrest due to his evading capture. The Provincial Prosecutor subsequently filed an information for murder in the RTC with a recommendation of bail, subsequently leading to the case being raffled to Judge Infante's Branch 38.
Judge Infante's Orders and Subsequent Actions
On April 23, 2003, Judge Infante issued two orders: one granting bail for P400,000.00 and another releasing Ancheta. On learning of these orders, Atty. Gacal petitioned for a reconsideration of the decision to grant bail. During the hearing held on April 29, 2003, Atty. Gacal claimed that the private prosecution lacked proper authorization under the Revised Rules of Criminal Procedure. Judge Infante directed the prosecution to submit a comment on the motion, which was not filed in a timely manner.
Legal and Procedural Issues
On May 21, 2003, Judge Infante denied Gacal's rebellion motion on procedural grounds, stating the lack of proper authorization of the private prosecutor and held the bail issue in abeyance pending comments from the public prosecutor. When the latter finally filed a comment on June 4, 2003, he maintained that the grant of bail was appropriate since the evidence did not warrant a strong case against Ancheta.
Complaint and Subsequent Proceedings
The complaint against Judge Infante for gross ignorance of the law, incompetence, and evident partiality culminated in administrative proceedings being filed by Atty. Gacal on August 5, 2003. The Office of the Court Administrator (OCA) and the Supreme Court embarked on a detailed investigation, seeking an explanation from Judge Infante for his actions regarding bail.
Judge Infante’s Defense
In his defense, Judge Infante maintained that he did not grant a petition for bail per se, but merely approved the bail bond posted as per the provincial prosecutor’s recommendation, emphasizing that no application for bail was lodged by Ancheta. However, this interpretation misconstrued the necessity of a hearing for bail in cases involving serious offenses such as murder.
Legal Standards Governing Bail
Under the 1987 Philippine Constitution and the Revised Rules of Criminal Procedure, a bail hearing is mandatory for capital offenses or those punishable by reclusion perpetua or life imprisonment when the evidence against the accused is str
...continue readingCase Syllabus (A.M. No. RTJ-04-1845)
Case Overview
- Complainant: Atty. Franklin G. Gacal, Private Prosecutor
- Respondent: Judge Jaime I. Infante, Regional Trial Court, Branch 38, Alabel, Sarangani
- Case Reference: A.M. No. RTJ-04-1845 (formerly A.M. No. IPI No. 03-1831-RTJ)
- Date of Decision: October 5, 2011
- Legal Issue: Allegations of gross ignorance of the law, gross incompetence, and evident partiality against Judge Infante for granting bail without a hearing in a murder case (Criminal Case No. 1136-03).
Background and Antecedents
- On March 18, 2003, Judge Gregorio R. Balanag, Jr. issued a warrant for the arrest of Faustino Ancheta for murder, with no bail recommended.
- Ancheta, who was hiding, was not apprehended immediately.
- The Office of the Provincial Prosecutor later filed an information for murder on April 21, 2003, recommending bail at P400,000.00.
- Criminal Case No. 1136-03 was raffled to Judge Infante, who on April 23, 2003, issued orders granting bail to Ancheta and immediately releasing him.
- Atty. Gacal filed a very urgent motion on April 25, 2003, seeking reconsideration of the bail grant and asserting that a hearing was necessary before bail could be granted.
Proceedings and Judge Infante's Actions
- April 29, 2003: Atty. Gacal's motion was discussed in court, but the public prosecutor did not appear. Judge Infante deferred the resolution of the motion until the prosecutor could comment.
- May 15, 2003: The arraignment was postponed due to the