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...

Facts:

Marriage to Jorge de Perio, Jr.

• On January 9, 1965, Lucena Escoto (also known as Crescencia Escoto) contracted marriage with Jorge de Perio, Jr. The marriage was solemnized before Mayor Liberato Reyna of Dagupan City. In the marriage contract, she used the name Crescencia Escoto and declared her civil status as single.

Divorce Decree

• On February 15, 1978, a document titled "Decree of Divorce" was issued by the Family District Court of Harris County, Texas (247th Judicial District). The decree dissolved the marriage between Jorge de Perio and Crescencia de Perio (Lucena Escoto).

Marriage to Manuel P. Diego

• On June 4, 1987, Lucena Escoto contracted another marriage with Manuel P. Diego, the brother of the complainant, Eduardo P. Diego. This marriage was solemnized before Rev. Fr. Clemente T. Godoy in Dagupan City. In this marriage contract, she used the name Lucena Escoto and again declared her civil status as single.

Criminal Case for Bigamy

• Lucena Escoto was charged with bigamy. On February 24, 1999, Judge Silverio Q. Castillo acquitted her, stating that the prosecution failed to prove her guilt beyond a reasonable doubt. The judge based the acquittal on the defense's claim that Lucena Escoto acted in good faith, believing her first marriage had been dissolved by the foreign divorce decree.

Issue:

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Ruling:

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Ratio:

1. Knowingly Rendering an Unjust Judgment: To hold a judge liable for knowingly rendering an unjust judgment, it must be proven that the judgment was unjust and that the judge knew it was unjust. In this case, there was no evidence of bad faith, malice, or corrupt intent on the part of Judge Castillo. Therefore, the charge of knowingly rendering an unjust judgment was dismissed.

2. Gross Ignorance of the Law: The Court found that Judge Castillo exhibited gross ignorance of the law by acquitting Lucena Escoto based on her alleged good faith. The Court reiterated that a mistake of law (such as believing a foreign divorce decree was valid in the Philippines) does not excuse criminal liability. The judge's failure to apply settled jurisprudence on bigamy and foreign divorce constituted gross ignorance of the law.

3. Penalty: The Court imposed a fine of P10,000 on Judge Castillo, consistent with the penalties for gross ignorance of the law at the time the decision was rendered. The Court also issued a stern warning that a repetition of similar acts would result in more severe penalties.