AM RTJ 03 1767; (March, 2003) (Digest)
A.M. No. RTJ-03-1767. March 28, 2003
ROSALIA DOCENA-CASPE, complainant, vs. JUDGE ARNULFO O. BUGTAS, Regional Trial Court, Branch II, Borongan, Eastern Samar, respondent.
FACTS
This administrative case for gross ignorance of the law stemmed from a murder case. Accused Celso Docil was charged with murder, a crime punishable by reclusion perpetua. In 1994, a previous judge granted bail to the accused without a hearing while they were at large. In 2000, after the accused’s apprehension, the prosecution moved to deny bail. Respondent Judge Bugtas initially denied the accused’s motion for bail, correctly ruling it was discretionary. However, upon a motion for reconsideration where the accused cited the 1994 order, and after the prosecution failed to file a comment within a given period, Judge Bugtas reversed himself. He issued a resolution on January 15, 2001, granting bail solely based on the prior, allegedly final, 1994 order, without conducting any hearing to determine if the evidence of guilt was strong.
ISSUE
Whether respondent Judge Arnulfo O. Bugtas is administratively liable for gross ignorance of the law for granting bail in a murder case without conducting the requisite hearing.
RULING
Yes, respondent Judge is administratively liable. The Supreme Court held that a hearing is mandatory in applications for bail for offenses punishable by reclusion perpetua, where bail is discretionary. This hearing is essential for the judge to exercise judicial discretion in determining whether the evidence of guilt is strong. The Court emphasized that this requirement cannot be dispensed with, even if the prosecution fails to object or adduce evidence, or if there exists a previous order granting bail. Reliance on a prior order is especially erroneous when, as here, that order was itself issued without a hearing and while the accused was at large. By granting bail based merely on the existence of the old order and the prosecution’s inaction, Judge Bugtas ignored settled jurisprudence and abdicated his duty to make an independent judicial determination. His act constituted gross ignorance of the law. Considering this was his second infraction, the Court imposed a fine of Twenty Thousand Pesos (P20,000.00) with a stern warning.