G.R. No. MTJ-96-1074 June 20, 1996
Spouses Alfredo and Felina Bio, Petitioners, vs. Judge Redentor Valera, Respondent.

FACTS

Complainant-spouses Alfredo and Felina Bio were charged with Qualified Theft (Criminal Case No. 5853) before the Municipal Trial Court (MTC) of Bangued, Abra, presided by respondent Judge Redentor Valera. The complaint was filed by Silvestre Castillo, a new landowner, based on an affidavit alleging the Bios cut trees from his land. The affidavit was subscribed before Judge Valera. The judge conducted a preliminary examination, found probable cause, and issued warrants of arrest against the Bio spouses and their son on the same day, resulting in their immediate apprehension.
The Bio spouses filed an administrative complaint, alleging Judge Valera gave undue benefit to Castillo by precipitately issuing the arrest warrants without affording them the right to submit counter-affidavits. They also highlighted the judge’s familial relation to a party interested in the underlying land dispute. Judge Valera defended his actions, stating he followed procedure under the 1985 Rules on Criminal Procedure. He later forwarded the case to the Provincial Prosecutor after realizing during trial that the acts might constitute a more serious offense under the Forestry Code.

ISSUE

Whether respondent Judge Redentor Valera is administratively liable for his handling of Criminal Case No. 5853 for Qualified Theft.

RULING

Yes, respondent Judge Valera is guilty of gross ignorance of the law and grave abuse of discretion. The Supreme Court affirmed the findings of the Deputy Court Administrator. First, the MTC had no jurisdiction to try the case for Qualified Theft, as the prescribed penalty exceeds six years imprisonment. Judge Valera should have merely conducted a preliminary investigation for purposes of filing an information in the proper Regional Trial Court, not assumed jurisdiction and arraigned the accused.
Second, he violated the proper procedure for preliminary investigation under Rule 112 of the 1985 Rules of Criminal Procedure. He failed to subpoena the respondents and furnish them a copy of the complaint to enable them to submit counter-affidavits. Instead, he issued arrest warrants on the very day he examined the complainant’s witness, depriving the accused of their procedural rights. His subsequent act of referring the case to the prosecutor only after trial had commenced further demonstrated his ignorance of jurisdictional limits and proper criminal procedure. Judges are duty-bound to master legal principles; ignorance of the law is the mainspring of injustice. He was fined P10,000.00 with a stern warning.