Case Summary (A.M. No. RTJ-02-1673)

Administrative Complaint Overview

• The case involves an administrative complaint against Judge Silverio Q. Castillo for allegedly rendering an unjust judgment in a criminal case concerning bigamy.
• The complainant, Eduardo P. Diego, asserts that the judge acted with gross ignorance of the law.

Background Facts of the 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 a Texas court, dissolving the marriage between Jorge de Perio and Crescencia de Perio.
• On June 4, 1987, Crescencia Escoto married Manuel P. Diego, using the name Lucena Escoto and again declaring her civil status as single.

Judgment and Acquittal

• On February 24, 1999, Judge Castillo acquitted Lucena Escoto of bigamy, stating that the prosecution failed to prove her guilt beyond a reasonable doubt.
• The judge based the acquittal on the accused's good faith, believing her first marriage was validly dissolved by the Texas divorce decree.

Complainant's Allegations

• The complainant argues that the judge's decision contradicts the law and the evidence presented.
• He questions the admissibility of the divorce decree and asserts that the evidence negates the finding of good faith.

Judge's Defense

• Judge Castillo acknowledged that the second marriage was technically bigamous but maintained that the accused honestly believed her first marriage was dissolved.
• He argued that the accused's lack of legal knowledge should not be equated with criminal intent.

Analysis of the Disputed Decision

• The court found that Judge Castillo failed to apply the law correctly regarding the bigamy case.
• The distinction between a mistake of fact and a mistake of law was emphasized, indicating that ignorance of the law does not excuse liability.

Knowingly Rendering an Unjust Judgment

• Knowingly rendering an unjust judgment is defined under Article 204 of the Revised Penal Code, requiring proof that the judgment is unjust and that the judge was aware of this.
• The court reiterated that good faith can be a defense against the charge of knowingly rendering an unjust judgment.

Gross Ignorance of the Law

• The court referenced previous cases to illustrate that not every erroneous decision warrants administrative accountability.
• A judge must exhibit gross or patent errors, malice, or deliberate misconduct to be held liable for gross ignorance of the law.

Application of Precedents

• The court concluded that the error made by Judge Castillo was gross and patent, constituting ignorance of the l...continue reading