G.R. No. A.M. No. 292-MJ September 9, 1975
RODOLFO GAMARA, CLODUALDO CASTRO and IGNACIO FLORES, complainants, vs. MUNICIPAL JUDGE GEMINIANO B. ALMEDA of Siniloan, Laguna, respondent.

FACTS

Patrolmen Rodolfo Gamara, Clodualdo Castro, Ignacio Flores, and Modesto Gamara were charged with double murder and atendado. Municipal Judge Geminiano B. Almeda, after a preliminary examination where Patrolmen Tereso Adaro and Claudio Gemanel testified, ordered their arrest and later denied petitions for bail. Subsequently, the fiscal filed an amended complaint to include Patrolman Adaro as a new defendant. Judge Almeda conducted a new preliminary examination on this amended charge.
In this examination, the prosecution presented Patrolman Gemanel as its sole witness. Gemanel merely reiterated his prior testimony, which did not implicate Adaro in the killings. Judge Almeda then ordered the fiscal to present more evidence, but the fiscal manifested he had none. The fiscal reintroduced only the sworn statements of other individuals, which did not directly incriminate Adaro. Consequently, in a resolution, Judge Almeda rejected the amended complaint, finding the evidence insufficient to establish a prima facie case against Adaro.

ISSUE

Whether respondent Judge Almeda is administratively liable for ignorance of the law, partiality, and grave abuse of discretion for rejecting the amended complaint against Patrolman Adaro.

RULING

The Court dismissed the administrative complaint and exonerated Judge Almeda. The legal logic is anchored on the judge’s discretionary power and duty during a preliminary investigation. A judge’s primary task at this stage is to determine whether sufficient evidence exists to establish probable cause and hold the accused for trial. The ruling clarifies that this is a judicial function requiring an assessment of the evidence presented.
Here, the prosecution’s sole witness failed to provide any testimony directly implicating Adaro. When directed to present further evidence, the fiscal could not offer any. Judge Almeda’s resolution was therefore a proper exercise of judicial discretion based on the insufficiency of the evidence before him. The Court found no evidence of malice, bias, or abuse of discretion. The investigator noted the complainants’ willingness to drop charges if the fiscal sustained the judge’s view, indicating a lack of sincerity. Furthermore, the complainants had an adequate legal remedy; they could have, and later did, request a reinvestigation by the provincial fiscal after the case was elevated to the Court of First Instance. Thus, the judge’s act of dismissing the amended complaint for lack of prima facie evidence was legally sound and not a ground for administrative sanction.