AC 3086; (May, 1989) (Digest)
A.C. No. 3086. May 3, 1989. IN RE: PETITION FOR THE DISMISSAL FROM SERVICE AND/OR DISBARMENT OF JUDGE BALTAZAR R. DIZON, PRESIDING JUDGE OF THE REGIONAL TRIAL COURT OF PASAY CITY, BRANCH 113. HON. ALEXANDER A. PADILLA, COMMISSIONER OF CUSTOMS, PETITIONER-COMPLAINANT.
FACTS:
This administrative case stems from a motion for reconsideration filed by respondent Judge Baltazar R. Dizon. He was previously found guilty and ordered dismissed from service by the Supreme Court in a Resolution dated February 23, 1988. The sole charge against him, brought by then Commissioner of Customs Alexander A. Padilla, was that he rendered a manifestly erroneous decision in Criminal Case No. 86-10126-P (People v. Lo Chi Fai) through gross incompetence and ignorance of the law. Judge Dizon acquitted Lo Chi Fai, who was apprehended with US$355,349.57 while boarding a flight to Hong Kong, for violating Central Bank Circular No. 960. The judge erroneously ruled that the prosecution needed to prove criminal intent, despite the offense being mala prohibita. He also ordered the return of US$3,000 from the seized amount based on a grossly wrong interpretation of the circular’s exemption clause.
In his motion for reconsideration, Judge Dizon admits his decision was erroneous but pleads it was made in good faith, not from a deliberate desire to pervert justice. He appeals for compassion, citing his over 26 years of government service, the devastating impact of dismissal on his family, and the loss of all benefits and future government employment.
ISSUE
Whether the penalty of dismissal from service imposed on Judge Dizon for gross ignorance of the law should be reconsidered and modified in light of his plea of good faith and other mitigating circumstances.
RULING
The Supreme Court granted the motion for reconsideration and modified the penalty. The Court reaffirmed the doctrine that a judge cannot be held administratively liable for an erroneous decision rendered in good faith. While it did not exonerate Judge Dizon, as his erroneous interpretation of a fundamental legal principle (that intent is not an element in mala prohibita offenses) was unjustified and reflected poorly on his competence, the Court found mitigating factors. Crucially, there was no clear indication from the records that his decision was inspired by corrupt motives or a reprehensible purpose to set a guilty party free. The error was one of gross misjudgment, not a deliberate twisting of facts.
The Court considered his long and dedicated government service, his humble submission and repentance, the absence of procedural transgressions in rendering the judgment, and the challenging working conditions of Metro Manila trial judges. It held that the period from the effectivity of his dismissal (February 23, 1988) to the promulgation of this resolution constituted sufficient punishment. Consequently, the Court ordered his reinstatement, effectively modifying the penalty to suspension without pay for that period.
