A.M. No. MTJ-93-842. May 10, 1995. MYLA PAREDES, ROWENA PAREDES, GLORIA PAREDES, and JESSICA PAREDES, complainants, vs. JUDGE JACINTO A. MANALO, Municipal Circuit Trial Court, Coron-Busuanga, Palawan, respondent.
FACTS

Complainants, the Paredes sisters, were charged in three separate criminal cases for less serious physical injuries and unjust vexation before the Municipal Trial Court of Culion, Palawan, where respondent Judge Jacinto A. Manalo was then the Acting Judge. On December 15, 1986, the same day the complaints were filed, respondent Judge immediately issued warrants for their arrest. The complainants, upon learning of the warrants, attempted to post cash bonds on December 26, 1986, but were unable to do so as the Municipal Treasurer refused acceptance without a specific Deposit Acceptance Order from the judge, who was then in Manila. Their subsequent attempts to post bail also failed, leading to their detention from December 27, 1986, until January 7, 1987.
The complainants alleged that the immediate issuance of warrants of arrest violated the Rule on Summary Procedure, which mandates that a subpoena should first be issued. They further contended that no bail should have been required for unjust vexation, a light offense penalized by arresto menor or a fine. Respondent Judge, in his defense, justified the immediate issuance of the warrants by expressing apprehension over the complainants’ possible flight, citing their history of being difficult to locate in a prior case. He argued that his action was a practical measure to ensure their presence and avoid delays in the proceedings.

ISSUE

Whether respondent Judge is administratively liable for ignorance of the law for immediately issuing warrants of arrest against the accused without first issuing subpoenas, in violation of the Rule on Summary Procedure.

RULING

Yes, respondent Judge is administratively liable. The Supreme Court found that respondent Judge disregarded the explicit procedure under Section 10 of the Rule on Summary Procedure. This rule clearly provides that upon the filing of a complaint or information for an offense covered by the rule, the court shall issue an order summoning the accused to appear. A warrant of arrest shall be issued only if the accused fails to appear despite service of the subpoena. The offenses charged against the complainants—less serious physical injuries and unjust vexation—are expressly governed by this summary procedure.
The Court rejected the judge’s justification of preventing flight as a valid reason to bypass the mandated sequence. His personal apprehension, based on the complainants’ alleged elusiveness in a previous case, did not constitute a legal exception to the rule. The procedure is designed precisely to avoid unnecessary deprivation of liberty for light offenses. The Court emphasized that judges must strictly adhere to procedural rules, as shortcuts, even if motivated by a desire to expedite proceedings, undermine the orderly administration of justice. While the Court noted that his intent to ensure the accused’s presence was a mitigating factor, it did not exonerate him from liability for ignoring a clear procedural mandate. Consequently, respondent Judge was fined P3,000.00 and sternly warned for his disregard of the Rule on Summary Procedure and the Code of Judicial Conduct.