G.R. No. OCA I.P.I. No. 95-62-RTJ. September 28, 1995
BELINDA LUISTRO MAÑOZCA, complainant, vs. JUDGE ROGER A. DOMAGAS, respondent.

FACTS

Complainant Belinda Luistro Mañozca charged respondent Judge Roger A. Domagas with gross ignorance of the law for granting a demurrer to evidence and acquitting the accused, Elmer de Jesus Mañozca, in a bigamy case. The prosecution had established that the accused contracted a second marriage a mere thirteen days after his first marriage to the complainant. In granting the demurrer, Judge Domagas relied on the U.S. v. Enriquez precedent, which acquitted an accused who had a reasonable belief his first spouse was dead, and on a notarized “Separation of Property with Renunciation of Rights” document executed by the spouses. The complainant argued this reliance was erroneous, as the factual circumstances negated any good faith or lack of fraudulent intent on the part of her husband.
While the administrative case was pending evaluation, respondent Judge Domagas passed away. Prior to this incident, he had been previously fined by the Supreme Court in two separate administrative cases for gross ignorance of the law, specifically for disregarding procedural rules on contempt and for granting bail without a hearing, and had been sternly warned.

ISSUE

Whether respondent Judge Roger A. Domagas is administratively liable for gross ignorance of the law for granting the demurrer to evidence in the bigamy case.

RULING

Yes, respondent Judge Domagas is administratively liable for gross ignorance of the law. The Supreme Court resolved the case notwithstanding his death, following precedent. The legal logic is clear: the grant of the demurrer was a patent misapplication of law. The cited U.S. v. Enriquez doctrine was inapplicable, as the factual basis for a finding of good faith—a reasonable belief the first spouse was dead—was utterly absent when the second marriage was contracted just days after the first. Furthermore, the judge himself noted in his order that the “Separation of Property” agreement was “contrary to law,” rendering it legally void and incapable of supporting a finding of good faith or lack of fraudulent intent. The accused’s actions—filing for annulment and executing the separation document before any judicial dissolution of the first marriage—manifestly demonstrated fraudulent intent, which is a key element of bigamy. By ignoring these glaring facts and legal principles, Judge Domagas exhibited a gross ignorance of fundamental law, compounding his record of prior similar infractions. Accordingly, the Court ordered the forfeiture of P5,000.00 from his retirement benefits as a penalty.