The Supreme Court’s decision in Gaspar Bandoy v. Judge Jose S. Jacinto, Jr. underscores the critical importance of judicial impartiality and strict adherence to procedural rules in court proceedings. The Court found Judge Jacinto guilty of gross ignorance of the law and procedure, as well as bias and partiality, for actions including holding an arraignment in chambers and displaying leniency toward one party. This ruling emphasizes that judges must not only be impartial but must also be perceived as such, ensuring public confidence in the judicial system. It serves as a reminder of the high standards expected of members of the bench.

Chambers Justice? When a Judge’s Actions Cast a Shadow on Impartiality

This case originated from an administrative complaint filed by Gaspar Bandoy against Judge Jose S. Jacinto, Jr., Presiding Judge of Branches 45 and Acting Presiding Judge of Branch 46 of the Regional Trial Court in San Jose, Occidental Mindoro. Bandoy alleged grave abuse of authority in relation to Criminal Case No. 2-1928, entitled “People of the Philippines v. Gaspar Bandoy, Peter Alfaro and Randolph Ignacio,” and Criminal Case No. Z-1910, entitled “People of the Philippines vs. Romulo De Jesus, Jr.” Bandoy’s complaint stemmed from his belief that Judge Jacinto, Jr. displayed bias and partiality in favor of Romulo De Jesus, Jr., particularly by granting numerous postponements of De Jesus, Jr.’s arraignment and eventually holding the arraignment in the judge’s chambers, rather than in open court as required by the rules.

Bandoy highlighted the history between him and De Jesus, Jr., rooted in election-related incidents. He alleged that De Jesus, Jr., a teacher, was caught in the act of ballot switching during the 2007 local elections. As a result, a criminal complaint for violation of the Omnibus Election Code was filed against De Jesus, Jr., in which Bandoy was instrumental. Subsequently, De Jesus, Jr. filed a criminal case for Serious Illegal Detention against Bandoy, which Bandoy perceived as retaliatory. Bandoy claimed that Judge Jacinto, Jr.’s leniency towards De Jesus, Jr., including the multiple postponements of his arraignment and the eventual holding of the arraignment in chambers, demonstrated a clear bias.

The Office of the Court Administrator (OCA) investigated the allegations. While the OCA did not find sufficient evidence to support Bandoy’s claims of an improper relationship between Judge Jacinto, Jr. and a local political family, it did note that Judge Jacinto, Jr. failed to refute the allegations regarding the arraignment being held in chambers and the leniency shown to De Jesus, Jr. This silence was interpreted as an admission of the facts. The OCA recommended that Judge Jacinto, Jr. be found guilty of bias and partiality, as well as gross ignorance of the law and procedure.

The Supreme Court, in its decision, emphasized the importance of adhering to Rule 116 of the Revised Rules of Court, specifically Section 1(a), which mandates that arraignments must be conducted in open court. The Court stated:

Section 1.  Arraignment and plea, how made. – (a) The accused must be arraigned before the court where the complaint or information was filed or assigned for trial.  The arraignment shall be made in open court by the judge or clerk by furnishing the accused with a copy of the complaint or information, reading the same in the language or dialect known to him, and asking him whether he pleads guilty or not guilty.  The prosecution may call at the trial witnesses other then those named in the complaint or information.

The Court found that Judge Jacinto, Jr.’s failure to conduct the arraignment in open court constituted gross ignorance of the law, as this procedural step is an integral part of the criminal litigation process. The Court also addressed the issue of bias and partiality, stating:

Canon 2, Rule 2.01 and Canon 3 of the Code of Judicial Conduct likewise emphasize that judges, as officers of the court, have the duty to see to it that justice is dispensed with evenly and fairly.  Not only must they be honest and impartial, but they must also appear to be honest and impartial in the dispensation of justice.  Judges should make sure that their acts are circumspect and do not arouse suspicion in the minds of the public.

The Court highlighted that the numerous postponements of De Jesus, Jr.’s arraignment without appropriate action from the court created an impression of bias and partiality, which undermined public confidence in the judiciary. The Court referenced the case of Joselito Rallos, et al., vs. Judge Ireneo Lee Gako Jr., Branch 5 RTC, Cebu City, underscoring that “judges should not only be impartial but should also appear impartial.” The Court also noted that judges must perform their duties in a manner free of any suspicion as to their fairness, impartiality, and integrity.

The Court emphasized that everyone, particularly a judge, is presumed to know the law and must maintain professional competence at all times. In conclusion, the Supreme Court found Judge Jose S. Jacinto, Jr. guilty of gross ignorance of the law and procedure, as well as bias and partiality. Consequently, he was fined P40,000.00 with a stern warning that a repetition of similar acts would be dealt with more severely. This decision is a reminder of the high standards of conduct expected of judges to maintain the integrity and impartiality of the judicial system.

FAQs

What was the key issue in this case?	The key issue was whether Judge Jacinto displayed gross ignorance of the law and procedure and exhibited bias and partiality in handling a criminal case, particularly in relation to the arraignment of one of the accused.
Why was Judge Jacinto found guilty?	Judge Jacinto was found guilty because he held an arraignment in his chambers instead of in open court, as required by the Revised Rules of Court. The Court also found his leniency towards one of the parties created an appearance of bias.
What does it mean to hold an arraignment in chambers?	Holding an arraignment in chambers means conducting the procedure in the judge’s private office rather than in the courtroom. This violates the rule that arraignments must be made in open court to ensure transparency and fairness.
What is the significance of the requirement that judges must “appear” impartial?	The requirement emphasizes that a judge’s conduct must not only be impartial but must also be perceived as such by the public. This is crucial for maintaining public confidence in the judiciary and ensuring that justice is administered fairly.
What is gross ignorance of the law?	Gross ignorance of the law occurs when a judge commits an error that is blatant, deliberate, or malicious. It can also arise when a judge ignores or contradicts established law and jurisprudence due to bad faith, fraud, dishonesty, or corruption.
What was the penalty imposed on Judge Jacinto?	Judge Jacinto was fined P40,000.00 and given a stern warning that any repetition of similar acts would result in more severe penalties.
What rule of the Revised Rules of Court did Judge Jacinto violate?	Judge Jacinto violated Rule 116, Section 1(a) of the Revised Rules of Court, which requires that arraignments be conducted in open court.
How does this case affect other judges in the Philippines?	This case serves as a reminder to all judges in the Philippines of the importance of adhering to procedural rules and maintaining impartiality in their conduct. It reinforces the principle that judges must not only be fair but also appear to be fair to the public.

The Supreme Court’s decision in Gaspar Bandoy v. Judge Jose S. Jacinto, Jr. reaffirms the judiciary’s commitment to upholding the highest standards of conduct among its members. The ruling serves as a critical reminder to all judges to strictly adhere to procedural rules and to conduct themselves in a manner that promotes and maintains public confidence in the impartiality and integrity of the judicial system.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: GASPAR BANDOY, COMPLAINANT, VS. JUDGE JOSE S. JACINTO, JR., PRESIDING JUDGE, BRANCH 45, AND ACTING PRESIDING JUDGE, BRANCH 46, BOTH AT REGIONAL TRIAL COURT, SAN JOSE, OCCIDENTAL MINDORO, RESPONDENT., A.M. No. RTJ-14-2399, November 19, 2014