ALEXANDER PADILLA VS. HONORABLE BALTAZAR R.

DIZON, PRESIDING JUDGE RTC PASAY CITY 113

(AM NO # 3086– February 23, 1988)

Facts of the Case:

This is the sequel of the decision of Presiding Judge of Pasay City RTC Baltaza Dizon on the case of
People of the Philippines vs. Lo Chi Fai regarding smuggling of foreign currency and foreign exchange
instruments when Lo Chi Fai hoped to return back from his trip here in our country bound to Hongkong.
Lo Chi Fai disclosed himself as a businessman who was trying to invest in our country for business
together with his associates. He also claimed that whenever him and his associates having business in
our country he was able to disclose all the declarations needed. When the time he was apprehended by
our enforcers in the airport, he did not disclosed these declarations since it did not allegedly required for
him to do and so and more so over, he cannot understand English language. In this case, Judge Dizon
acquitted the respondent as it did not intend the accused to do so the crime. Alexander Padilla, a
Commissioner on Bureau of Customs filed a case of Administrative againts Pasay City Presiding Judge
Baltazar R. Dizon on the grounds of erroneous decision and gross negligence againsts the law for
acquitting Lo Chi Fai, a tourist, in an offense of smuggling of foreign currency in violation of Central Bank
Circular No. 960 Sec 6 out of the country. It was noted that the decision of the Judge was made
September 29, 1986 but the the complaint to the respondent Lo Chi Fai was filed only on August 6, 1987
that only showed a malice and ill-will interest. Dizon prays for the dismissal of the petition as if he
render the decision in “good faith”.

Issue:

Whether or not Dizon had a criminal liability

Whether or not an erroneous decision rendered in good faith is acceptable to rules of law

Ruling:

Yes, Dizon had a criminal liability

A judge CAN NOT BE HELD to account or answer, criminally, civilly, or administratively, for an
ERRONEOUS decision rendered by him IN GOOD FAITH

Ignoratio juris non excusat is applied.

Decision:

Supreme Court finds GUILTY of GROSS NEGLIGENCES, INCOMPETENCE, GROSS IGNORANCE OF THE LAW,
GRAVE AND SERIOUS MISCONDUCT AFFECTING HIS DIGNITY AND INTEGRITY.

DISMISSED FROM THE SERVICE.