Case Summary (A.M. No. RTJ-05-1946)
Allegations Against the Respondent
The complainants accused Judge How of gross ignorance of the law, manifest partiality, and serious misconduct in his handling of their petition for bail. Notably, they claimed that the judge wrongly denied bail based on inadequate reasoning and without allowing the defense the opportunity to present its own evidence.
Procedural History
The sequence of events began with the filing of charges against the complainants after a prosecutor initially withdrew the information based on DOJ recommendations. Following the Supreme Court’s directive for the trial court to resume proceedings, the case was assigned to Judge How, who then conducted hearings for the bail petition.
Judge's Conduct During the Hearing
During the bail hearings, Judge How allowed the prosecution to present evidence but dismissed the defense's request to present its evidence, considering it misplaced. On December 29, 2004, he denied the bail petition, citing that the evidence of guilt was strong, but the complainants contended that this conclusion lacked supporting detail or thorough evaluation.
Respondent's Defense
In his defense, Judge How argued that as per legal standards for bail hearings, only the prosecution was required to provide evidence at that stage, and he believed he exercised his discretion correctly. He asserted that any error was one of judgment made in good faith, which did not constitute misconduct.
Evaluation by Office of the Court Administrator (OCA)
The OCA determined that the hearing required both parties to present evidence to thoroughly assess the strength of the prosecution's case. It concluded that Judge How’s refusal to allow the defense to present evidence constituted a disregard for due process rights, resulting in a deficiency in his judicial prudence and discretion.
Legal Principles Regarding Bail
According to Section 13, Article III of the 1987 Philippine Constitution, individuals charged with capital offenses can be denied bail if the evidence of guilt is strong. However, a judicial determination must precede this, considering evidence from both sides to fairly decide if bail should be granted.
Findings of the Committee
Upon review, the committee noted that while the respondent's decision to cut short the hearing and deny
...continue readingCase Syllabus (A.M. No. RTJ-05-1946)
Case Background
- The case arises from an administrative complaint filed on January 31, 2005, by complainants Ligaya V. Santos, Edna Cortez, Girlie Castillo, and Christopher Castillo against Judge Rolando G. How of the Regional Trial Court, Branch 257, Parañaque City.
- The complaint alleges Gross Ignorance of the Law, Manifest Partiality, and Serious Misconduct in relation to Criminal Case Nos. 01-0921 and 01-0425, where the complainants were accused of involvement in ambush incidents against the sons of Assistant City Prosecutor Domingo I. Orda, Jr.
- The complainants, who include a barangay chairwoman and councilors, were detained without bail during the prosecution's case.
Procedural History
- The Parañaque City Prosecutor's Office initially found probable cause but the Department of Justice later recommended dismissal, which was granted by the trial court.
- This withdrawal was nullified by the Court of Appeals, leading to the arrest of the complainants.
- A motion to inhibit the original presiding judge for partiality was filed, resulting in the reassignment of the case to Judge Rolando G. How.
- During a bail hearing, the prosecution presented witnesses who implicated the complainants, leading to a petition for bail which was eventually denied by the respondent judge.
Issues Raised
- The primary issues revo