Vicente v. Majaducon
REITERATIONFacts
The Antecedents: Dante Vicente filed a letter-complaint against Judge Jose S. Majaducon for gross ignorance of the law, grave abuse of authority, and manifest partiality. The complaint stemmed from a series of criminal cases involving Evelyn Te, who was found guilty on four counts of violating B.P. Blg. 22 and sentenced to two months imprisonment for each count. The decision became final and executory. Procedural History: Te sought clarification on serving her sentences successively or simultaneously. The trial court clarified they should be served successively but, for humanitarian reasons and in accordance with Article 70 of the Revised Penal Code, reduced the total imprisonment from eight months to six months. Te then filed a motion for reconsideration, also treated as a petition for a writ of habeas corpus, citing Vaca v. Court of Appeals and arguing for sentence modification and immediate release. She also argued denial of equal protection due to a judge in another case directing simultaneous service of sentences. The trial court denied the habeas corpus petition, stating Te was detained by virtue of a final judgment. Te subsequently filed an omnibus motion for release, claiming she had served the minimum of her total sentence. She also moved for reconsideration of the denial of habeas corpus, arguing finality did not bar the application, and prayed for bail pending determination of the Vaca ruling's applicability. The trial court allowed Te to post bail for one million pesos, certifying the proceedings to the Supreme Court. The bail was later approved at ₱500,000.00, and Te was ordered released. The Assistant City Prosecutor moved for reconsideration, which was denied. Te filed a notice of appeal, but the trial court denied due course, stating the records were forwarded to the Supreme Court. The Petition: The complainant alleged that the respondent judge improperly allowed Te's release and confinement in a hospital, approved bail in habeas corpus proceedings despite no petition being filed, and retaliated against media criticism by citing mediamen for indirect contempt. The complainant also alleged the judge released another accused without bail. The complainant prayed for the judge's investigation, termination, and removal from service.
Issue(s)
Whether the respondent judge committed gross ignorance of the law in granting bail to Evelyn Te, who was already serving a sentence by reason of a final judgment, and whether he erred in certifying the case to the Supreme Court under Rule 102, Section 14, when the applicant was serving a sentence by reason of a final judgment. Whether the respondent judge acted with gross ignorance of the law in allowing Te's confinement in a hospital. Whether the respondent judge acted with gross ignorance of the law in citing mediamen for indirect contempt.
Ruling
The Supreme Court found the respondent judge guilty of gross ignorance of the law or procedure. The Court ordered the respondent judge to pay a FINE of ₱40,000.00, to be deducted from the ₱100,000.00 set aside from his retirement benefits.
Ratio Decidendi
On the issue of granting bail to Evelyn Te after final judgment and certifying the case to the Supreme Court under Rule 102, Section 14: The Court held that Section 24, Rule 114 of the Rules of Court explicitly prohibits the grant of bail after a judgment has become final and the convict has started to serve the sentence, with the sole exception of applying for probation before commencing service of sentence, provided the penalty and offense are within the Probation Law's purview. Evelyn Te's judgment was final and executory, she did not apply for probation, and she was already serving her sentence when the respondent judge granted her bail. Therefore, Te was not entitled to bail. The respondent judge's contention that he had discretion under Section 14, Rule 102 of the Rules of Court was rejected, as this provision applies only to cases where the applicant is restrained by virtue of a criminal charge, not when serving a sentence by reason of a final judgment. The Court reiterated its pronouncement in a prior resolution that the certification of a case under Rule 102, Section 14, is erroneous when the applicant is serving a sentence by reason of a final judgment. The Court found the certification of the case to the Supreme Court under Rule 102, Section 14, to be clearly erroneous. The Court clarified that this provision applies to cases where the applicant for the writ of habeas corpus is restrained by virtue of a criminal charge against him, not where, as in Evelyn Te's case, she was serving a sentence by reason of a final judgment. Rule 102, Section 4, disallows the issuance of the writ where the person is suffering imprisonment under a lawful judgment. The respondent judge's explanation that he was trying to avoid potential charges of ignorance of the law or abuse of discretion by certifying the case to the Supreme Court was deemed shallow and unjustified, as judges cannot shirk responsibility by passing the buck. On the issue of hospital confinement: The Court found no sufficient evidence to prove that the respondent judge improperly allowed Te's release and confinement at a local hospital on account of false illnesses. Records showed the confinement was recommended by government doctors and made without objection from the public prosecutor, thus upholding the presumption of regularity in the performance of official duty. On the issue of citing mediamen for contempt: The Court found nothing irregular or arbitrary in the judge's act of requiring journalists to show cause why they should not be cited for indirect contempt. The Court stated that freedom of speech is not absolute and must be balanced with the need to maintain the integrity of courts and the orderly administration of justice. The judge was exercising his right to protect his honor and the integrity of the court.
Main Doctrine
A judge who grants bail to a convict serving a sentence by reason of a final judgment, in disregard of Section 24, Rule 114 of the Rules of Court, commits gross ignorance of the law. The writ of habeas corpus under Rule 102, Section 14, is not applicable to individuals already serving sentence by virtue of a final judgment.