Padilla vs. Dizon

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Facts:

This is an administrative complaint then Commissioner of Customs, Alexander Padilla, against


Judge Baltazar R. Dizon for rendering a manifestly erroneous decision due, at the very least, to
gross incompetence and gross ignorance of the law "People of the Philippines vs. Lo Chi Fai",
acquitting said accused of the offense charged due to lack of criminal intention, i.e., smuggling
of foreign currency out of the country. Judge alleges that he did it in good faith and that he has a
commendable record and is a fearless prosecutor.
Issue:
Is Judge Dizon liable for gross incompetence and gross ignorance of the law?
Ruling:
The respondent-judge has shown gross incompetence or gross ignorance of the law in holding
that to convict the accused for violation of Central Bank Circular No. 960, the prosecution must
establish that the accused had the criminal intent to violate the law. The respondent ought to
know that proof of malice or deliberate intent (mens rea) is not essential in offenses punished by
special laws, which are mala prohibita. The circumstances which make the story concocted by
the accused so palpably unbelievable as to render the findings of the respondent judge obviously
contrived to favor the acquittal of the accused, thereby clearly negating his claim that he
rendered the decision "in good faith."

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