Diego v. Castillo
REITERATIONFacts
The Antecedents: Accused Lucena Escoto contracted a marriage on January 9, 1965, with Jorge de Perio, Jr., using the name Crescencia Escoto and stating her civil status as single. Subsequently, on February 15, 1978, a "Decree of Divorce" was purportedly issued by the Family District Court of Harris County, Texas, dissolving the marriage between Jorge de Perio and Crescencia de Perio. Thereafter, on June 4, 1987, the same accused, now using the name Lucena Escoto and stating her civil status as single, contracted a second marriage with Manuel P. Diego. Procedural History: A criminal case for bigamy was filed against Lucena Escoto. The respondent Judge, Silverio Q. Castillo, acquitted the accused on February 24, 1999, citing the accused's good faith belief that her previous marriage had been validly dissolved by the foreign divorce decree. The respondent Judge reasoned that the charge was mala in se, requiring criminal intent, and that the accused, as an ordinary laywoman, entertained the impression that she could contract a subsequent marriage after receiving the divorce decree. The Petition: The complainant alleged that the respondent Judge knowingly rendered an unjust judgment and/or rendered judgment in gross ignorance of the law, as the decision was manifestly against the law and the evidence. The complainant questioned the evidentiary weight and admissibility of the divorce decree and argued that the evidence negated the finding of good faith.
Issue(s)
Whether the respondent Judge knowingly rendered an unjust judgment. Whether the respondent Judge rendered judgment in gross ignorance of the law.
Ruling
The Supreme Court found no basis for the charge of knowingly rendering an unjust judgment but held the respondent Judge liable for gross ignorance of the law. The respondent Judge was fined P10,000.00 with a stern warning.
Ratio Decidendi
On Whether the respondent Judge knowingly rendered an unjust judgment: The Court held that there was no basis for this charge. To be liable for knowingly rendering an unjust judgment, it must be proven that the judgment is unjust, contrary to law or unsupported by evidence, and that the judge knew it was unjust, acting with conscious and deliberate intent to do injustice. Good faith on the part of the judge is a defense. In this case, while the judgment might have been erroneous, there was no evidence presented to show that the respondent Judge acted with malice, bad faith, or a corrupt purpose. The complainant failed to prove the element of conscious and deliberate intent to do injustice. On Whether the respondent Judge rendered judgment in gross ignorance of the law: The Court found that the respondent Judge committed gross ignorance of the law. The respondent Judge's decision to acquit the accused based on her good faith belief in the validity of a foreign divorce decree, despite established jurisprudence to the contrary, demonstrated a failure to apply settled legal principles. The Court cited People v. Bitdu and People v. Schneckenburger, which clearly held that foreign divorces are not recognized in the Philippines and that ignorance of the law, even for a layperson, does not excuse liability for bigamy. The respondent Judge's reasoning that the accused acted in good faith due to a "mistake of fact" was contrary to established jurisprudence which classifies reliance on a foreign divorce decree as a mistake of law, not fact. This error was considered gross and patent, warranting disciplinary action.
Main Doctrine
A judge who acquits an accused in a bigamy case based on the accused's good faith belief that a foreign divorce decree validly dissolved the first marriage, despite established jurisprudence holding that foreign divorces are not recognized in the Philippines and that ignorance of the law is not a defense, commits gross ignorance of the law. Such an error, being gross and patent, warrants disciplinary action.