Case Digest (A.M. No. RTJ-02-1673)
Facts:
- Eduardo P. Diego filed an administrative complaint against Judge Silverio Q. Castillo of the Regional Trial Court, Branch 43, Dagupan City, on August 11, 2004.
- The complaint alleged that Judge Castillo rendered an unjust judgment and acted in gross ignorance of the law in a bigamy case.
- Lucena Escoto married Jorge de Perio, Jr. on January 9, 1965, using the name Crescencia Escoto and declaring her civil status as single.
- A divorce decree was issued on February 15, 1978, by the Family District Court of Harris County, Texas, dissolving the marriage.
- On June 4, 1987, Crescencia Escoto married Manuel P. Diego, the complainant's brother, again declaring her civil status as single.
- Judge Castillo acquitted the accused on February 24, 1999, citing good faith, believing the Texas divorce decree was valid.
- The complainant argued that the divorce decree should not be recognized in the Philippines, where divorce is not acknowledged.
- Judge Castillo maintained that the accused's honest belief was crucial in determining her culpability.
Issue:
- (Unlock)
Ruling:
- The court found no basis for the charge of knowingly rendering an unjust judgment against Judge Castillo.
- The court acknowledged that Judge Castillo's error was gross and patent, warranting disciplinary action, resulting ...(Unlock)
Ratio:
- For a judge to be liable for knowingly rendering an unjust judgment, it must be proven that the judgment was unjust and that the judge was aware of this.
- The complainant did not demonstrate that Judge Castillo acted with malice or bad faith, which are essential for such a charge.
- The judge's belief in the accused's good faith was considered a valid factor, as good faith can defend against claims of unjust judgment.
- The court referenced prior jurisprudence, stati...continue reading
Case Digest (A.M. No. RTJ-02-1673)
Facts:
This case involves an administrative complaint filed by Eduardo P. Diego against Judge Silverio Q. Castillo of the Regional Trial Court, Branch 43, Dagupan City. The complaint, dated August 11, 2004, alleges that Judge Castillo knowingly rendered an unjust judgment and/or acted in gross ignorance of the law in a criminal case concerning bigamy. The events leading to the complaint began on January 9, 1965, when Lucena Escoto married Jorge de Perio, Jr. in Dagupan City, using the name Crescencia Escoto and declaring her civil status as single. On February 15, 1978, a divorce decree was issued by the Family District Court of Harris County, Texas, which purportedly dissolved the marriage between Jorge de Perio and Crescencia de Perio. Subsequently, on June 4, 1987, Crescencia Escoto married Manuel P. Diego, the complainant's brother, again using the name Lucena Escoto and again declaring her civil status as single.
In the criminal case for bigamy, Judge Castillo rendered a decision on February 24, 1999, acquitting the accused on the grounds of good faith, asserting that she believed her first marriage had been validly dissolved by the Texas divorce decree. The judge acknowledged that while the marriage bond was not annulled under Philippine law, the accused acted without malicious intent, believing she was legally free to marry again. The complainant, Eduardo P. Diego, contended that the judge's decision was contrary to law and evidence, arguing...