G.R. No. MTJ-96-1080, August 22, 1996
Antonio Sandoval, Complainant, vs. Judge Jacinto Manalo, Respondent.

FACTS

Complainant Antonio Sandoval’s son, Alexander, was killed. A criminal complaint for murder was filed against Jermaine Echague in the Municipal Circuit Trial Court (MCTC) of Coron-Busuanga, Palawan, presided by respondent Judge Jacinto Manalo. The judge issued a warrant of arrest with no bail recommended. After the accused was arrested and failed to submit counter-affidavits, Judge Manalo issued an order finding a prima facie case and directing the transmittal of the records to the Provincial Prosecutor, with instructions for the accused to be delivered to the provincial warden.
Subsequently, the accused’s counsel filed a motion to lift the warrant of arrest, arguing the accused would not flee. On the same day the motion was filed, without notice to the prosecution, Judge Manalo granted it, ordering the accused’s release to his counsel’s custody. Later, a separate case for illegal possession of firearms (the weapon used in the killing) was filed against the same accused. Judge Manalo issued a warrant for this new case with a P150,000 bail, but the accused could no longer be found.

ISSUE

Whether respondent Judge Manalo is administratively liable for gross ignorance of the law, grave abuse of authority, and dereliction of duty in lifting the warrant of arrest and releasing the accused in the murder case.

RULING

Yes, the respondent judge is administratively liable. The Supreme Court found Judge Manalo guilty of misconduct or grave abuse of authority. The legal logic is clear: once a judge conducting a preliminary investigation finds a prima facie case and orders the case forwarded to the prosecutor for the filing of an information, as Judge Manalo did in his June 8 order, his authority over the accused becomes limited. The release of an accused at that juncture is governed by the rules applicable after the filing of an information in the proper court, not by the provisions on pre-investigation custody under Rule 112.
By lifting the warrant and releasing the accused to private custody based on a motion filed on the same day without notifying the prosecution, Judge Manalo disregarded established procedure. His act effectively nullified his own prior finding of a prima facie case for a non-bailable offense and facilitated the accused’s evasion of the subsequent warrant in the related illegal firearms case. This demonstrated not mere error in judgment, but bad faith and a deliberate disregard of the law to accommodate the accused, constituting grave abuse of authority. The Court imposed a fine of P5,000.00 and issued a stern warning.