Title
Supreme Court
Spouses Rafols vs. Dizon
Case
A.M. No. RTJ-98-1426
Decision Date
Jan 31, 2006
Judge Teodoro Dizon was dismissed for demanding and receiving P150,000 in exchange for a favorable ruling, violating judicial integrity and ethics.

Case Digest (A.M. No. RTJ-98-1426)
Expanded Legal Reasoning Model

Facts:

  • Initiation of the Administrative Complaint
    • A letter dated March 24, 1998, from the Integrated Bar of the Philippines, South Cotabato-Sarangani-General Santos City Chapter, was sent to the Board of Governors of the Integrated Bar of the Philippines.
    • The letter alleged a judicial anomaly in the complainants' area of responsibility concerning Judge Teodoro A. Dizon and Atty. Ricardo G. Barrios, Jr., prompting the need for an administrative investigation.
    • The allegations were detailed in a joint affidavit executed on March 3, 1998 by Manuel C. Rafols, Jr. and Lolita B. Rafols, and were supported by additional affidavits from Larry Sevilla, Allan Rafols, and Daisy Rafols.
  • Procedural Developments and Court Administrative Actions
    • Upon receipt of the letter by Ms. Erlinda C. Verzosa, then Deputy Clerk of Court and Bar Confidant, the case was referred for appropriate action.
    • Senior Deputy Court Administrator Reynaldo L. Suarez filed an Administrative Matter for Agenda recommending:
      • Immediate docketing of the matter.
      • Furnishing Judge Dizon with copies of the attachments and directing him to answer the charges within ten days.
      • Preventive suspension of Judge Dizon pending the investigation.
      • Designation of an Acting Presiding Judge in his stead.
      • Referral of Atty. Barrios’ conduct for a separate investigation by the Office of the Bar Confidant.
    • The Court approved these recommendations in a resolution dated October 21, 1998.
  • Developments on the Health and Subsequent Administrative Handling
    • On December 18, 1998, Mrs. Aurora M. Dizon, the wife of Judge Dizon, informed the Court of her husband’s serious physical condition (an ischemic stroke) and requested that the investigation be suspended pending his recuperation.
    • The Court, in a resolution dated February 8, 1999, referred the matter for further evaluation by the Office of the Court Administrator.
    • Based on the evaluation, further recommendations were made on procedural terms, including the suggestion that Judge Dizon be provided with necessary retirement forms should he opt for retirement on grounds of total disability.
    • The recommendations were approved in a subsequent resolution dated March 17, 1999.
  • Submission of Comments and Assignment for Investigation
    • Respondent Judge Dizon filed a comment on May 11, 1999, categorically denying the allegations.
    • The Court referred the case for further investigation to Associate Justice Wenceslao I. Agnir, Jr. of the Court of Appeals.
    • At the request of Justice Agnir, and considering Judge Dizon’s physical disability, the investigation was transferred to Associate Justice Jose L. Sabio, Jr.
  • Presentation and Contradictions of Witness Testimonies
    • Atty. Ricardo Barrios, Jr. provided two contradicting written statements:
      • An affidavit dated January 28, 1998, exonerating Judge Dizon by alleging that the judge did not demand money to settle the case.
      • A later letter dated February 24, 1998, in which he repudiated his earlier affidavit and admitted that Judge Dizon had indeed demanded money.
    • Complainant Manuel C. Rafols, Jr. testified in detail regarding:
      • The sequence of events in which Judge Dizon, through his emissaries, demanded an initial sum and later additional money for a favorable resolution in Civil Case No. 6209.
      • The methods and circumstances under which money was delivered, including meetings at a hotel and subsequent communications demanding further fees.
    • Corroborative testimonies were rendered by:
      • Engineer Allan Rafols, who confirmed the handling and source of the funds.
      • Daisy Rafols, who attested to the origin of part of the money used.
      • Larry Sevilla, a newspaperman who corroborated the existence of an exposé on the judge’s and lawyer’s misconduct.
    • Defense witnesses, including Jaime Quizan and Judge Dizon himself, offered testimony:
      • Jaime Quizan denied involvement in collecting money on behalf of the judge.
      • Judge Dizon reiterated his blanket denial of any wrongdoing.
    • A subsequent rebuttal by Manuel C. Rafols, Jr. clarified inconsistencies regarding the identity of the driver, asserting that a person named Dodong—a separate individual—was the actual driver involved in facilitating the collection of money.
  • Recommendations and Final Findings of the Investigative Bodies
    • Associate Justice Jose L. Sabio, Jr. recommended that:
      • In view of Judge Dizon’s poor health and the initiation of the extortion scheme by complainants’ counsel, the judge be allowed to retire under disability retirement.
      • Judge Dizon should return the extorted amount as restitution.
      • An investigation be conducted into Atty. Barrios’ conduct.
    • In contrast, the Office of the Court Administrator recommended:
      • The dismissal of Judge Dizon from the service with forfeiture of all benefits (except leave credits), emphasizing judicial integrity.
    • The Court, after review, found that:
      • The complainants’ testimonies, supported by documentary evidence and multiple corroborative witnesses, established that Judge Dizon demanded money in exchange for a favorable judgment.
      • The judge's denial, even though vehemently stated, was unsubstantiated by clear and convincing evidence.
      • The conduct amounted to direct bribery and constituted gross judicial misconduct, warranting severe sanctions.

Issues:

  • Whether Judge Teodoro A. Dizon engaged in judicial misconduct by demanding and receiving money from litigants in exchange for favorable judgments.
    • Was there sufficient and credible evidence to substantiate the allegations of extortion and bribery against the judge?
    • Did the actions of Judge Dizon and the contradictory statements of Atty. Barrios amount to violations of the Code of Judicial Conduct and Section 8 of Rule 140 of the Rules of Court?
  • The appropriateness of the sanctions imposed or recommended.
    • Should Judge Dizon be dismissed from the service with forfeiture of benefits, given the gravity of the misconduct?
    • Is the preventive suspension and subsequent administrative handling in keeping with established judicial disciplinary procedures?
    • What are the implications for the legal profession and public confidence in the integrity of the judiciary?
  • The admissibility and relative weight of the defenses and rebuttals offered.
    • Can Judge Dizon’s blanket denial, unsupported by contradictory evidence, be given more weight than the credible testimonies of the complainants and their witnesses?
    • How should the contradictory statements of Atty. Barrios be reconciled in light of the overall evidence?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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