Sixty-Day Suspension of Arraignment

In pronouncing that Judge Madrona acted in grave abuse of discretion when he failed to defer the arraignment of the respondent, the Court of Appeals cited Solar Team Entertainment, Inc. v. Judge How, wherein this Court cautioned judges to refrain from precipitately arraigning the accused to avoid any miscarriage of justice. However, this case was decided before the Rules of Criminal Procedure were revised on 1 December 2000; and the rule setting the 60-day period for the suspension of the arraignment of the accused pending an appeal or a petition for review before a reviewing authority was not yet applicable. (Dino v. Olivarez, G.R. No. 172400, June 23, 2009)