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Diego v. Castillo

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Diego v. Castillo

Case Title and Citation

Eduardo P. Diego, complainant, vs. Judge Silverio Q. Castillo, Regional Trial Court, Dagupan City, Branch 43, respondent.
A.M. No. RTJ-02-1673, August 11, 2004
Supreme Court - First Division
Ponente: Justice Azcuna

Facts

  • On January 9, 1965, accused Lucena Escoto contracted marriage with Jorge de Perio, Jr., solemnized before the then Mayor of Dagupan City. The couple were Filipinos. In the marriage contract, the accused used and adopted the name Crescencia Escoto, with a civil status of single.
  • On February 15, 1978, a document denominated as a “Decree of Divorce” purportedly issued to Jorge de Perio as petitioner by the Family District Court of Harris County, Texas (247th Judicial District), declared the bonds of matrimony between Jorge de Perio and Crescencia de Perio dissolved, cancelled and annulled, and the Petitioner granted a divorce.
  • On June 4, 1987, the same Crescencia Escoto contracted marriage with complainant Manuel P. Diego, solemnized before a parish priest in Dagupan City. The marriage contract shows that she used the name Lucena Escoto, with a civil status of single.
  • After trial of the criminal case for bigamy, the respondent Judge promulgated a decision on February 24, 1999, acquitting the accused: “Wherefore, for failure of the STATE to prove accused’s guilt beyond whisper of doubt, the COURT hereby orders her ACQUITTAL with costs de oficio. SO ORDERED.”
  • The decision credited the defense that the accused acted in good faith and believed the divorce decree rendered her legally free to remarry. The judge observed that: cessation of the matrimonial bond between Jorge de Perio and the accused was decreed by the Texas court effective February 15, 1978.
  • The charge was Mala en se, requiring criminal intent. The defense argued the accused believed she was not violating the law due to the foreign divorce.
  • The complainant contends the decision was contrary to law and evidence, arguing that the divorce decree should not serve as a basis for good faith. The judge acknowledged that the second marriage was bigamous since divorce is not recognized in the Philippines and the first husband was alive.
  • The court noted that the disputed ruling treated the issue as a mistake of fact rather than a mistake of law, distinguishing between the two and noting that everyone is presumed to know the law; a mistake of law does not excuse criminal liability.
  • The Office of the Court Administrator recommended reprimand with stern warning; the case proceeded to determine whether the judge’s action constituted knowingly rendering an unjust judgment or gross ignorance of the law.

Issues

  1. Did Respondent Judge knowingly render an unjust judgment in the bigamy case?
  2. Did Respondent Judge commit gross ignorance of the law in his disposition acquitting the accused?

Ruling

  1. No — There is no basis for concluding that the judge knowingly rendered an unjust judgment. The judge relied on a good-faith defense and recognized the accused’s claimed lack of malice, and good faith can negate the element of bad faith required for knowingly rendering an unjust judgment.
  2. Yes — The conduct constitutes gross ignorance of the law. The judge treated the matter as a mistake of fact and relied on a foreign divorce decree to conclude that the marriage was dissolved, which is inconsistent with Philippine law and prior jurisprudence. The error was found to be gross and patent, warranting disciplinary action.

Reasoning / Ratio Decidendi

  • Knowingly rendering an unjust judgment requires proof that the judgment is unjust and that the judge knew it was unjust; good faith can be a defense. See: Article 204, People v. Bitdu (mistake of fact vs. mistake of law distinction), and Alforte v. Santos (good faith defense to bad faith accusations).
  • The court recognized that a mistake of fact (believing there was a valid divorce) does not excuse a criminal act like bigamy, but the crucial issue for the first charge (knowingly rendering an unjust judgment) is the presence of malice or bad faith, which the complainant failed to prove.
  • The case discusses that a judge is not penalized for every erroneous decision; sanctions apply only where the error is gross or patent, with evident bad faith or gross ignorance of the law. See Wingarts v. Mejia; Guillermo v. Reyes, Jr.; Mañozca v. Domagas; and related jurisprudence.
  • The court emphasized that the reliance on a foreign divorce decree and treating it as controlling under Philippine law constitutes gross ignorance of the law; the Philippines does not recognize foreign decrees to automatically dissolve a marriage, and a judge must apply Philippine law rather than foreign judgments. The standard for gross ignorance is illustrated by Mañozca v. Domagas and related cases, with the Court applying penalties under the then-existing guidelines (A.M. No. 01-8-10-SC) and similar authorities.
  • The decision cites that “knowledge of the law should not be exacted strictly from a lay person,” but nonetheless, a judge must apply the law correctly and cannot substitute foreign judgments for Philippine law without proper basis. See Ubarra v. Mapalad and Louis Vuitton S.A. v. Villanueva.

Doctrine / Legal Principle

  • Good faith as a defense to knowingly rendering an unjust judgment; lack of malice or corrupt motive can exonerate in the charge of knowingly rendering an unjust judgment.
  • Mistake of fact may not excuse bigamy, but mistake of law does not excuse criminal liability; everyone is presumed to know the law.
  • Gross ignorance of the law is a valid ground for administrative discipline when the error is gross and patent, showing a lack of due care in applying the law.
  • A judge’s error may be sanctioned if it reveals a failure to exercise due care and proper legal interpretation; not every erroneous decision warrants sanctions, but gross ignorance or malice does.

Disposition

  • The RTC Judge Silverio Q. Castillo is fined Ten Thousand Pesos (P10,000) with a stern warning that repetition will be dealt with more severely.
  • The complaint as to knowingly rendering an unjust judgment was not sustained; the sanction applied was for gross ignorance of the law.

Concurring / Dissenting Opinions

  • There were no separate concurring or dissenting opinions; the decision states that Justices Davide, Jr., Quisumbing, Ynares-Santiago, and Carpio concurred in the result.

Significance / Notes

  • Reaffirms that good faith can be a defense to findings of culpability for knowingly unjust judgments, but it does not relieve a judge from other potential accountability for errors.
  • Establishes that gross ignorance of the law, when the judge misapplies or misinterprets law to a degree that is gross and patent, is a disciplinary matter warranting sanctions.
  • Highlights the caution required by judges when interpreting foreign court orders or foreign decrees, ensuring accuracy in applying Philippine law.
  • Emphasizes the balance between not harassing judges for every erroneous ruling and ensuring accountability for clear and gross legal misapplications.
Judicial Ethics Judicial Misconduct Public Officers Criminal Law
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