A.M. No. RTJ-93-1088. January 18, 1995. TERESITA ARMI R. GUILLERMO, complainant, vs. JUDGE JOSE C. REYES, JR., Regional Trial Court, Branch 76, San Mateo, Rizal, respondent.
FACTS

Complainant Teresita Armi R. Guillermo, a physician, charged respondent Judge Jose C. Reyes, Jr. with knowingly rendering an unjust judgment, gross incompetence, misconduct, and ignorance of the law. The complaint stemmed from Criminal Case No. 1996 for serious illegal detention filed against Aurora Ilot-De la Cruz and Annie Ilot-Orgeta, who allegedly locked complainant and her assistant in her clinic. Respondent judge initially denied the accused’s application for bail as premature since they were not in custody. However, upon their voluntary appearance, he granted bail without conducting a new hearing, denying the prosecution an opportunity to oppose. Subsequently, respondent judge acquitted the accused, holding that the facts only constituted unjust vexation, which had prescribed, rather than serious illegal detention.

ISSUE

Whether respondent judge is administratively liable for his actions in granting bail and rendering the judgment of acquittal.

RULING

The Court found respondent judge administratively liable for his procedural lapses in granting bail but not for the acquittal. For charges punishable by reclusion perpetua, like serious illegal detention, bail is discretionary, not a right. When bail is discretionary, a hearing is mandatory to allow the prosecution to prove that evidence of guilt is strong, and the order must contain a summary of the evidence. Respondent correctly denied the initial bail application for prematurity. However, upon the accused’s surrender, he erred by granting bail without conducting a new hearing and without a requisite evidentiary summary in his order. This procedural shortcut created an impression of undue favor.
Nonetheless, the Court found no gross ignorance of the law in the acquittal. A judge is not administratively accountable for every erroneous judgment, provided the error is not gross, patent, malicious, or in bad faith. The acquittal was based on his interpretation that the accused acted out of “anger and annoyance” without intent to deprive liberty, constituting only unjust vexation. Absent proof of fraud, malice, or deliberate intent to distort the law, his judicial error is not an administrative offense. Good faith is a sufficient defense. However, for his failure to observe proper procedure in granting bail, respondent judge is REPRIMANDED with a STERN WARNING.