Case Summary (A.M. No. RTJ-99-1453)
Background of the Case
On February 25, 1992, Demetria Pedrano was shot and her mother, Basilia, was murdered in their home, leading to the filing of criminal charges against Nenito Gadonan. The cases were adjudicated by Judge Barte, who on January 20, 1995, acquitted Gadonan due to reasonable doubt. Following the verdict, the Pedrano family, with Fr. Sinnot, filed a letter-complaint claiming Judge Barte's bias toward Gadonan due to alleged personal ties. They sought a retrial based on claims that the judge ignored substantial evidence against Gadonan.
Proceedings and Allegations
After the complainants raised concerns of bias, the Supreme Court required Judge Barte to submit a comment. He denied any prejudice, asserting that no motion to inhibit him had been filed during the trial. Judge Barte contended that the complainants were responsible for the lack of key witness testimonies that could have enhanced the prosecution’s case. He also disclosed that one of Gadonan's daughters had worked as his househelper but claimed this relationship had ended before the trial.
Investigation and Findings
Fr. Sinnot later alleged threats to his life related to the administrative case and provided an affidavit from Vicente Gerebise, a process server who suggested Judge Barte had solicited him to hire killers to target Fr. Sinnot and others. Further NBI investigations revealed a relationship between Judge Barte and Richel Gadunan, a daughter of Nenito Gadonan, which resulted in a child. Despite producing evidence of this relationship, the NBI found insufficient proof regarding the murder case and allegations of attempted murder against Fr. Sinnot.
Conduct of the Administrative Proceedings
The administrative complaint process included several hearings wherein various witnesses provided testimonies regarding Judge Barte's conduct. Evidence, including letters and birth certificates linked to the judge’s dealings with Richel, indicated inconsistencies in his denigrations of the NBI investigator's credibility. None of the substantial evidence presented sufficiently proved that Judge Barte acted with bias in relation to the murder case against Gadonan.
Judicial Standards and Outcome
The investigation determined that while the evidence showed a lack of propriety in Judge Barte’s perso
...continue readingCase Syllabus (A.M. No. RTJ-99-1453)
Background of the Case
- An administrative complaint was filed against Judge Recaredo P. Barte for bias and partiality in his decision to acquit Nenito Gadonan in a double murder case.
- The double murder involved the killings of Demetria Pedrano and her mother, Basilia Pedrano, on February 25, 1992.
- Demetria was shot, and Basilia was hacked to death by assailants who waited at their residence.
- Only Lolita Pedrano Pingkian, a seven-year-old niece, survived by fleeing.
Proceedings and Allegations
- State prosecutors charged Nenito Gadonan with two counts of murder, which were assigned to Judge Barte’s court.
- On January 20, 1995, Judge Barte acquitted Gadonan on the grounds of reasonable doubt.
- The complainants, including family members of the victims and Fr. Michael Sinnott, filed a complaint with the Supreme Court, alleging Judge Barte's bias due to alleged personal relationships with the accused's family.
Complainants' Claims
- Complainants claimed overwhelming evidence against Gadonan was disregarded by Judge Barte.
- Allegations surfaced that Judge Barte had a personal relationship with a daughter of Gadonan and that Gadonan's other daughter worked as Barte’s house helper.
- The complainants requested a mistrial and a retrial based on these claims.
Judge Barte’s Defense
- Judge Barte countered the allegations, asserting he would have inhibited himself if a formal request had been made.
- He denied any bias and claimed that the accusations were unfounded r