G.R. No. MTJ-99-1231; March 17, 2004
Antonio Gamas and Florencio Sobrio, complainants, vs. Judge Orlando A. Oco and SPO4 Willie Adulacion, respondents.

FACTS

Complainants, accused of theft, went to the Municipal Trial Court of Polomolok to post bail. They allege that respondent police prosecutor Adulacion enticed them to plead guilty and apply for probation to avoid jail, presenting a pre-drafted decision. Respondent Judge Oco allegedly signed this draft without conducting a proper arraignment, merely telling complainants to plead guilty. A court clerk read the document, which complainants signed upon Adulacion’s assurance they would be used as witnesses. They later discovered it was an order finding them guilty and sentencing them to imprisonment. Upon securing counsel, the order was vacated for improvident pleas. Complainants filed an administrative complaint for grave misconduct and gross ignorance of the law, asserting their rights to counsel and proper arraignment were violated.
Respondent Judge denied the irregularities. In his Answer, he claimed he personally explained their constitutional rights, conducted an on-the-spot arraignment where he read the information, and that complainants voluntarily pleaded guilty, begging for minimum penalty and probation. He asserted he handwritten the decision in their presence, had it typed, read back by an interpreter, and only then did complainants sign it. He maintained the process was regular and responsive to their immediate desire to avoid detention.

ISSUE

Whether respondent Judge is administratively liable for gross ignorance of the law and grave misconduct in convicting the accused without a valid arraignment and in violation of their right to counsel.

RULING

Yes, respondent Judge is administratively liable for gross ignorance of the law. The Supreme Court found his version of events improbable and indicative of a blatant disregard for fundamental criminal procedure. A valid arraignment requires the reading of the complaint or information in a language understood by the accused and requiring them to plead. The Judge’s alleged instantaneous, informal arraignment, conducted without the presence of counsel for the indigent accused and culminating in immediate sentencing, grossly violates constitutional and procedural safeguards. The right to counsel is indispensable, especially during arraignment and when entering a plea. The Judge’s claim of explaining rights is negated by the absence of a counsel and the rushed, irregular nature of the proceeding, which effectively denied complainants due process.
The Court emphasized that judges must adhere strictly to procedural rules to protect the rights of the accused. Respondent Judge’s actions demonstrated a serious, inexcusable deficiency in his grasp of basic legal principles, constituting gross ignorance of the law. He was fined P20,000. The case against SPO4 Adulacion was referred to the National Police Commission for appropriate action, as the administrative jurisdiction over police prosecutors lies with the executive branch.