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 Summary (G.R. No. 126749)

Allegations and Administrative Complaint

The case was initiated by a letter from the Integrated Bar of the Philippines, highlighting an alleged judicial anomaly involving Judge Teodoro D. Dizon and Atty. Ricardo G. Barrios, Jr. The complaint alleged that Judge Dizon demanded a bribe of ₱150,000 from the Rafols to ensure a favorable decision in Civil Case No. 6209. This claim was substantiated by a joint affidavit executed by the complainants, alongside additional witness affidavits.

Preliminary Investigatory Steps

The complaint was referred to the then-Court Administrator Alfredo L. Benipayo, who requested an investigation. The Court ordered preventative suspension for Judge Dizon pending the results of the investigation. A replacement presiding judge was appointed to handle his docketed cases.

Health Issues and Procedural Delays

In December 1998, Judge Dizon's wife informed the Court of her husband’s poor health following an ischemic stroke, requesting a delay in the investigation. The Court acknowledged the request but later decided against lifting the suspension for lack of merit, urging that Judge Dizon be assisted in filing for retirement due to total disability.

Testimonies of the Complainants

Several testimonies highlighted the alleged demand for bribes. The complainants stated that they were directly solicited by Judge Dizon for funds to ensure a favorable ruling. Various amounts were exchanged, including an initial payment of ₱50,000 and further demands leading to a total of ₱130,000, alongside attempts by Dizon to solicit additional payments.

Contradictory Statements and Witness Accounts

Atty. Barrios provided contradictory statements on several occasions. Initially, he exonerated Judge Dizon, claiming the judge never solicited money. However, his subsequent affidavit presented a stark reversal, implicating Judge Dizon in the bribery charges. Further testimonies from family members of the Rafols corroborated their account of being coerced into making payments.

Defense and Counterarguments

In defense, Judge Dizon vehemently denied allegations and attempted to discredit the testimonies against him, emphasizing a lack of concrete evidence linking him to the bribe solicitation. His defense included testimonies from utility worker Jaime Quizan, who denied any involvement in transporting money related to the bribe claims.

Investigative Findings and Recommendations

The case was investigated by Justice Jose L. Sabio, Jr., who concluded misconduct on Judge Dizon's part. Despite acknowledging the severity of misconduct, the Investigating Justice advised compassion due to Dizon's health condition. The findings included a recommendation for resignation due to disability, alongside restitution

...continue reading

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources. AI digests are study aids only—use responsibly.