Magleo v. De Juan-Quinagoran
REITERATIONFacts
The Antecedents: This administrative case originated from a complaint filed by Esther P. Magleo, the accused in Criminal Case No. 137860-PSG for Estafa, against respondent Judge Rowena De Juan-Quinagoran and Branch Clerk of Court Atty. Adonis Laure. Magleo accused the respondents of Gross Misconduct, Gross Partiality, Acts Unbecoming a Member of the Judiciary, Violation of the Code of Judicial Conduct, and Conduct Unbecoming a Court Personnel. The underlying dispute involved a criminal case where Magleo was charged with Estafa under Article 315, paragraph 1(b) of the Revised Penal Code. Procedural History: The complainant, Esther P. Magleo, was initially acquitted in Criminal Case No. 137860-PSG by Judge Nicanor Manalo, Jr. via a demurrer to evidence. However, after a motion to inhibit Judge Manalo, the case was re-raffled to Branch 166 of the Regional Trial Court, Pasig City, presided over by respondent Judge De Juan-Quinagoran. Respondent judge overturned the acquittal, prompting Magleo to file a motion for reconsideration, which was denied. Subsequently, Magleo filed a petition for certiorari with the Court of Appeals (CA) challenging the respondent judge's orders. The CA dismissed this petition. Magleo was later arrested pursuant to a warrant issued by the respondent judge, but was subsequently released after a motion to lift the warrant was filed and granted. The Petition: Magleo's administrative complaint alleged that the respondent judge committed gross ignorance of the law and evident partiality by overturning the acquittal, thereby violating her right against double jeopardy. She also claimed the judge violated the Code of Judicial Conduct by failing to provide notice of a hearing, leading to her arrest, and by issuing a warrant of arrest without a specified bail amount. Furthermore, she alleged discourtesy and hostility from the respondent clerk of court and other court personnel. The respondents countered that the demurrer to evidence was premature, the notice of hearing was properly served, the warrant of arrest was a consequence of Magleo's failure to appear, and the court personnel's actions were justified or denied. The Supreme Court, in its review, found no merit in the claims of gross partiality and violations of the Code of Judicial Conduct, concluding that the respondent judge acted within the bounds of law and jurisprudence, though the court personnel were admonished for discourtesy.
Issue(s)
Whether the respondent judge committed gross ignorance of the law and evident partiality by overturning the order granting the demurrer to evidence, thereby violating the complainant's right against double jeopardy. Whether the respondent judge violated the Code of Judicial Conduct by allegedly failing to serve the notice of hearing for June 8, 2011. Whether the respondent judge violated the Code of Judicial Conduct by issuing a bench warrant without a specified bail amount and by not motu proprio lifting the warrant. Whether the respondent Clerk of Court and court personnel committed acts unbecoming of court personnel due to alleged discourtesy.
Ruling
The complaint is DISMISSED for lack of merit. Respondents and their court personnel are ADMONISHED to be always courteous in dealing with litigants and the public in the performance of official duties.
Ratio Decidendi
On the claim of gross partiality for reversing an Order Granting the Demurrer to Evidence: The Court found that the respondent judge acted in accordance with law and jurisprudence. The demurrer to evidence was filed prematurely, before the prosecution rested its case. The RTC had not yet ruled on the admissibility of the formal offer of evidence when the demurrer was filed. Therefore, the respondent judge had a legal basis to overturn the order granting the demurrer to evidence, as there was no proper acquittal. The Court cited Bautista v. Cuneta-Pangilinan and People v. Laguio, Jr., emphasizing that double jeopardy does not attach when the trial court acted with grave abuse of discretion, such as denying the prosecution the opportunity to present its case, as in this instance where the demurrer was prematurely granted. The CA had also dismissed the complainant's petition for certiorari on this matter. On the claim of violation of the Code of Judicial Conduct for not serving the Notice of Hearing: The Court gave credence to the respondents' documentary proofs, which included a Constancia with return cards, the court calendar, and a Post Office Certification, all indicating that the complainant and her counsel were duly notified of the June 8, 2011 hearing. The Court found the complainant's bare allegation of non-receipt to be unconvincing compared to the substantiated claims of the respondents. Therefore, her failure to attend the hearing was deemed a deliberate attempt to ignore the trial date, and the consequences were attributable to her alone. On the claim of violation of the Code of Judicial Conduct for issuing a Bench Warrant: The Court held that the issuance of a bench warrant was a valid consequence of the complainant's failure to attend the June 8, 2011 hearing, despite being duly notified. The warrant did not state a bail bond because the complainant had allegedly jumped bail, leading to the forfeiture of her original bail bond. The Court clarified that the Rules of Court do not require the amount of a new bail bond to be stated in the bench warrant itself. Furthermore, the Court found no mandate for a judge to motu proprio lift a warrant of arrest upon mere expression of intent to post bail; a formal motion is required. Respondent judge acted properly by requiring the filing of an ex parte motion to lift the order of arrest, which she then promptly granted. On the claim of performing Acts Unbecoming of a Judge and Court Personnel due to discourtesy: While the allegations of discourtesy were not fully substantiated, the Court disagreed with the respondents' stance that such remarks should be tolerated or considered justified. The Court emphasized that all court personnel, including judges and clerks of court, are expected to be courteous and professional, as they mirror the image of the Judiciary. The Court admonished the respondents and their court personnel to avoid impolite language and improper tone, and to uphold professionalism, respect, good manners, and right conduct.
Main Doctrine
A demurrer to evidence filed before the prosecution rests its case is premature and its subsequent granting does not constitute an acquittal that would bar further proceedings on the ground of double jeopardy. The issuance of a bench warrant for failure to appear at a duly notified hearing is a valid consequence, and the subsequent fixing of bail upon motion is proper procedure.