Cortes v. Catral (1997)
Cortes v. Catral (1997)
Cortes v. Catral (1997)
Catral (1997)
Facts: A sworn letter complaint was filed by Flaviano Cortes charging Judge Segundo B. Catral of the RTC
of Aparri, Cagayan with Gross Ignorance of the Law committed as follows:
1. He granted bail in murder cases without hearing: People v. Duerme, for murder and People v. Rodrigo
Bumanglag for murder;
2. On May 3, 1995, Barangay Captain Rodolfo Castanedas for Illegal Possession of Firearm was raffled
and assigned to his sala. The provincial prosecutor granted a bailbond of P180,000.00 but it was reduced
by Judge Segundo Catral for only P30,000.00. No hearing has been made from 1995 to the present
because according to his clerks, he is holding it in abeyance;
3. Another Barangay Captain Nilo de Rivera with a homicide case was granted with a bailbond
of P14,800.00 by Judge Segundo Catral. The amount is too low; and,
4. Jimmy Siriban the right hand man of Julio Bong Dicierto was sued for concubinage and convicted by
Judge Herminio del Castillo in MTC. Jimmy Siriban appealed and it was elevated to the RTC Branch 08,
the sala of Judge Segundo Catral. Judge Segundo Catral acquitted Jimmy Siriban.
Issue 1: Whether or not Gross Ignorance of the Law was committed by Judge Catral, for granting bail in
murder cases without hearing in People v. Duerme and in People v. Dumanglag.
Issue 2: Whether or not Gross Ignorance of the Law was committed by Judge Catral, for granting a bail
bond of P14,800.00 in favor of Brgy. Capt. de Rivera with a homicide case, an amount complained of to
be too low.
Ruling 1: YES. When a person is charged with an offense punishable by death, reclusion perpetua or life
imprisonment, bail is a matter of discretion (This is implemented under Rule 114, Sec. 7 of the Rules of
Court). Consequently, when the accused is charged with an offense punishable by death, reculusion
perpetua or life imprisonment, the judge is mandated to conduct a hearing, whether summary or
otherwise in the discretion of the court, not only to take into account the guidelines set forth in Sec. 9,
Rule 114 of the Rules of Court, but primarily to determine the existence of strong evidence of guilt or
lack of it, against the accused.
A summary hearing means such brief and speedy method of receiving and considering the evidence of
guilt as is practicable and consistent with the purpose of hearing which is merely to determine the
weight of evidence for purposes of bail. On such hearing, the court does not sit to try the merits or to
enter into any nice inquiry as to the weight that ought to be allowed to the evidence for or against the
accused, nor will it speculate on the outcome of the trial or on what further evidence may be therein
offered or admitted. The course of inquiry may be left to the discretion of the court which may confine
itself to receiving such evidence as has reference to substantial matters, avoiding unnecessary
thoroughness in the examination and cross examination.The reason for this is plain. Inasmuch as the
determination of whether or not the evidence of guilt against the accused is strong is a matter of judicial
discretion, it may rightly be exercised only after the evidence is submitted to the court at the
hearing. Since the discretion is directed to the weight of evidence and since evidence cannot properly be
weighed if not duly exhibited or produced before the court, it is obvious that a proper exercise of
judicial discretion requires that the evidence of guilt be submitted to the court, the petitioner having the
right of cross examination and to introduce evidence in his own rebuttal.
Ruling 2: NO. As long as in the fixing of the amount of bail, the Court is guided by the purpose for which
bail is required, that is, to secure the appearance of the accused to answer charges brought against him,
the decision of the court to grant bail in the sum it deems appropriate will not be interfered with.
Respondent judge added that the amount of bail was appropriate inasmuch as it was fixed in
accordance with the guidelines set forth in Section 9 of Administrative Circular 12-94.