G.R. No. RTJ-03-1780. September 14, 2005
AMADO L. DE LEON, Complainant, vs. JUDGE PATROCINIO R. CORPUZ, Respondent.

FACTS

Complainant Amado L. De Leon charged respondent Judge Patrocinio Corpuz of the RTC, Branch 44, San Fernando City, Pampanga, with grave abuse of authority. The allegation stemmed from the judge’s approval of the bail application of Noe dela Fuente on April 10, 2002. The accused was facing multiple counts of estafa and violations of B.P. Blg. 22 before the Municipal Trial Court (MTC), Branch 2, Guagua, Pampanga. The complainant asserted that the presiding judge of the MTC, Judge Jesusa Mylene C. Suba-Isip, was present and available in her court on that day, making her the proper judicial officer to act on the bail application under the rules.
Respondent judge, in his comment, denied any irregularity. He explained that the accused, accompanied by a police officer, appeared before him near the close of office hours, claiming that no judges were available in the courts of Guagua and that he was the only judge present in San Fernando City. Based on this representation and after finding the bail bond in order, respondent issued the approval order.

ISSUE

Whether respondent Judge Patrocinio Corpuz committed gross misconduct by approving an application for bail outside the authority granted by procedural rules.

RULING

Yes, the Supreme Court found respondent judge guilty of gross misconduct. The legal logic centers on a clear violation of Section 17, Rule 114 of the Rules of Criminal Procedure, which governs where bail may be filed. The rule provides that bail should be filed with the court where the case is pending. Only in the absence or unavailability of that judge may it be filed with another judge within the same province, city, or municipality. The accused was arrested in Guagua, the same municipality where his cases were pending before MTC Judge Isip. The investigation confirmed Judge Isip was present and available the whole day. Therefore, the exclusive authority to approve the bail rested with her MTC, not with an RTC judge in a different city.
The Court emphasized that respondent, given his long judicial service, ought to have known this basic procedural rule. His failure to verify the alleged absence or unavailability of the proper MTC judge, or to ascertain if other MTC judges within the province were available, constituted a blatant disregard of established law. This transgression of a definite rule of action amounts to gross misconduct, which is a serious charge under the Rules of Court. The act demonstrated a lack of the diligence and integrity required by the Code of Judicial Conduct, thereby tarnishing the judiciary’s image. Consequently, the Court imposed a fine of Forty Thousand Pesos (₱40,000.00) to be deducted from his retirement benefits.