Title
Supreme Court
Pantillo III vs. Canoy
Case
A.M. No. RTJ-11-2262
Decision Date
Feb 9, 2011
Judge Canoy violated bail procedures by releasing accused without written application, proper deposit, or formal charge, leading to a fine and warning.

Case Summary (G.R. No. 212815)

Facts of the Case

On September 3, 2008, Pantilo, whose brother was the homicide victim, attended inquest proceedings involving Melgazo. Later that evening, he was informed that Melgazo had been released from detention after posting bail of PhP 30,000, authorized by Judge Canoy. However, Pantilo was surprised to discover the following day that no formal charge had been filed against Melgazo, and that the release was based on a verbal order from Judge Canoy rather than a written one.

Procedures Surrounding Bail

On September 5, 2008, Melgazo filed a Motion for the Release of his impounded vehicle, but the hearing took place without proper notice to Pantilo, violating the three-day notice requirement under the rules. Judge Canoy issued an order allowing the prosecutor three days to comment but subsequently granted the motion despite the prosecutor's opposition, leading Pantilo to file a motion for inhibition against Judge Canoy, which was denied.

Judge's Response to the Complaint

Upon receipt of Pantilo's complaint, Judge Canoy defended his actions by emphasizing the constitutional right to bail. He contended that he acted in light of exceptional circumstances, as the physical release of Melgazo was justified despite procedural lapses. He maintained that a "constructive bail" was effectively granted and that he intended to process the necessary paperwork the following day.

Court Administrator's Evaluation

In evaluating the case, the Court Administrator found that Judge Canoy had indeed failed to follow the mandated procedures for granting bail as set out in the Revised Rules on Criminal Procedure. The judge's verbal order without a written application or acknowledgment of the required procedures constituted a breach of judicial conduct.

Judicia

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