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Crim Law 1 Case Digest: Diego v. Castillo 2004

Diego v. Castillo

A.M. No. RTJ-02-1673  August 11, 2004

Lessons Applicable: malice, bigamy

Laws Applicable: Article 204[7] RPC,

FACTS:
·         January 9, 1965: Crescencia Escoto contracted marriage with Jorge de Perio, Jr., both Filipinos, solemnized before then Mayor Liberato Reyna of Dagupan City
·         February 15, 1978: Jorge filed a Decree of Divorce in Texas
·         June 4, 1987: Crescencia Escoto using the name Lucena Escoto married Manuel P. Diego before the Rev. Fr. Godoy, parish priest of Dagupan City
·         The sister of Manuel P. Diego filed a criminal case of bigamy against Escoto
·         RTC: Acquittal since state failed to prove guilt beyond whisper of a doubt and gave credence to the defense of the accused that she acted without any malicious intent for believing in good faith that her marriage was already annulled by a foreign judgment
·         An administrative case is filed against Judge Silverio Q. Castillo for Knowingly rendering an unjust judgment under Article 204[7] of the Revised Penal Code

ISSUE: W/N Castillo should be liable against Article 204[7] of the Revised Penal Code

HELD: NO. Regional Trial Court Judge Silverio Q. Castillo is FINED P10,000 with a STERN WARNING that a repetition of the same or similar acts will be dealt with more severely
·         The law requires that
o    (a) the offender is a judge;
o    (b) he renders a judgment in a case submitted to him for decision;
o    (c) the judgment is unjust;
o    (d) he knew that said judgment is unjust
·         even assuming that a judge erred in acquitting an accused, he still cannot be administratively charged lacking the element of bad faith, malice or corrupt purpose
·         As a matter of public policy then, the acts of a judge in his official capacity are not subject to disciplinary action, even though such acts are erroneous. 
·         Good faith and absence of malice, corrupt motives or improper considerations are sufficient defenses in which a judge charged with ignorance of the law can find refuge.
·         error committed by respondent Judge being gross and patent, the same constitutes ignorance of the law of a nature sufficient to warrant disciplinary action