G.R. No. RTJ-98-1426. January 31, 2006
MANUEL C. RAFOLS, JR. and LOLITA B. RAFOLS, complainants, vs. JUDGE TEODORO A. DIZON, respondent.

FACTS

The Integrated Bar of the Philippines (IBP) South Cotabato-Sarangani-General Santos City Chapter forwarded a complaint against Judge Teodoro A. Dizon of the RTC, Branch 37, General Santos City, and Atty. Ricardo G. Barrios, Jr., alleging judicial anomaly. The complainants, spouses Manuel and Lolita Rafols, executed a joint affidavit stating that Judge Dizon, through Atty. Barrios, demanded P150,000.00 in exchange for a favorable decision in their civil case, with an assurance of victory up to the Court of Appeals. The complaint was supported by corroborating affidavits from other witnesses. The Court docketed the administrative matter, preventively suspended Judge Dizon, and required his comment.
Despite a plea for leniency due to the respondent’s serious illness (ischemic stroke), the Court denied the lifting of his preventive suspension. Judge Dizon eventually filed a comment denying the allegations. The case was referred to an investigating justice of the Court of Appeals. During the investigation, key witness Atty. Barrios presented contradictory affidavits—one exonerating the judge and another implicating him in the bribery scheme.

ISSUE

Whether respondent Judge Teodoro A. Dizon is administratively liable for serious misconduct, specifically for bribery and gross violation of the Code of Judicial Conduct.

RULING

Yes, respondent Judge Teodoro A. Dizon is administratively liable and is DISMISSED from service. The investigating justice and the Office of the Court Administrator found the complainants’ evidence credible and sufficient to establish the charges. The detailed and consistent testimonies of the complainants and their witnesses, who were present during the illicit meeting at a hotel coffee shop, convincingly proved that Judge Dizon solicited and received money in consideration for a favorable ruling. The Court emphasized that in administrative proceedings, only substantial evidence is required, not proof beyond reasonable doubt.
The act of demanding money in exchange for a judicial decision constitutes direct bribery, a serious charge under the Rules of Court. It is a gross misconduct that violates the Code of Judicial Conduct and irreparably tarnishes the integrity of the judiciary. The Court has consistently held that such egregious acts warrant the supreme penalty of dismissal to preserve public confidence in the courts. Judge Dizon’s actions demonstrated utter disregard for ethical standards and betrayed the public trust. Consequently, he was dismissed with forfeiture of all benefits, except accrued leave credits, and with prejudice to re-employment in any government agency.