A.M. No. RTJ-02-1673 - Diego vs. Castillo

On January 9, 1965, the accused, originally identified as Crescencia Escoto, contracted a marriage with Jorge de Perio, Jr. in Dagupan City before then Mayor Liberato Reyna.
Both parties were Filipino, and in the marriage contract, the accused declared herself as single despite the use of a particular name.

On February 15, 1978, a document entitled “Decree of Divorce” was issued by the Family District Court of Harris County, Texas (247th Judicial District).
The decree ordered the dissolution, cancellation, and annulment of the matrimonial bonds between Jorge de Perio and Crescencia de Perio, thereby purportedly freeing the accused from her marital obligations.
The divorce decree was later presented by the accused as the basis of her belief that her prior marriage had been legally terminated.

On June 4, 1987, the accused, this time using the name Lucena Escoto, contracted a marriage with Manuel P. Diego, who is identified as the brother of the complainant.
The marriage was solemnized by Rev. Fr. Clemente T. Godoy in Dagupan City, and the contract once again showed her civil status as single.

The accused was charged with bigamy under the criminal case for contracting a subsequent marriage while her first marriage still subsisted.
On February 24, 1999, the respondent Regional Trial Court Judge, Silverio Q. Castillo, rendered a decision.
The decision acquitted the accused on the main ground that she acted in good faith, having believed that the divorce decree validly dissolved her first marriage.
The court emphasized that the element of criminal intent (dolo), essential for bigamy under the Revised Penal Code, was lacking due to the accused’s honest mistake.

The respondent Judge credited the defense’s evidence—both testimonial and documentary—with establishing that the accused’s belief in the validity of the divorce was genuine.
He reasoned that although Philippine law does not recognize foreign divorce decrees, the fact that the decree from Harris County indicated the cessation of the first marriage provided the accused with sufficient grounds to believe she was free to remarry.
The decision rested on the distinction between a mistake of fact (good faith belief based on the divorce decree) and a mistake of law, emphasizing that ignorance of the law (a presumption that everyone knows the law) does not automatically excuse criminal conduct.

Complainant Eduardo P. Diego argued that the respondent Judge’s acquittal was manifestly against law and evidence.
The complainant contested the evidentiary weight and admissibility of the divorce decree as a basis for determining the accused’s good faith, asserting that the record negated such a defense.
He pressed that the decision of the respondent Judge amounted to knowingly rendering an unjust judgment and/or showing gross ignorance of the law, thereby calling for administrative sanctions.

The case made reference to People v. Bitdu, which distinguished between a mistake of fact (potentially a defense) and a mistake of law (not excusable), reinforcing that ignorance of the law does not relieve criminal responsibility.
People v. Schneckenburger was also cited, affirming that reliance on a foreign divorce decree does not exonerate one from liability for bigamy.
The judicial standards for administrative liability of a judge were highlighted, requiring proof that the judge knew his decision was unjust, acted with malice, or exhibited gross ignorance of the law.

The Office of the Court Administrator (OCA) recommended that the judge be reprimanded and issued a stern warning, taking into account the error committed in the interpretation and application of the law regarding bigamy.
The final sanction imposed was a fine of Ten Thousand Pesos (P10,000), accompanied by a stern warning that any repetition of such conduct would be addressed more severely.

Whether the respondent Judge should be held liable for knowingly rendering an unjust judgment by acquitting the accused despite evidence suggesting cruelty to the law.
Whether the judge’s decision exhibited gross ignorance of the law, particularly in light of established jurisprudence on the non-recognition of foreign divorce decrees in determining bigamy.
Whether the accused’s reliance on a foreign divorce decree, and the subsequent belief that she was free to contract a new marriage, legitimately constitutes a defense of good faith in a bigamy case.
Whether the evidentiary weight and admissibility of the divorce decree were properly evaluated in support of the accused’s good faith defense.
Whether the administrative complaint against the judge is justified based on the elements of malice, bad faith, or gross error in the application of the law.