Ronquillo v. Amparo
REITERATIONFacts
1. The Antecedents: The underlying dispute involved a civil case where the plaintiff, Juanita Ronquillo, sought damages against Maria de Castro and Alto Surety & Insurance Co., Inc. The trial court ruled in favor of the defendants, absolving them of the claims. The plaintiff was notified of this decision on March 27, 1954. 2. Procedural History: Following the adverse decision, the plaintiff filed a motion for reconsideration and new trial on April 14, 1954, which was denied on May 3, 1954. She was notified of this denial on May 8, 1954. Subsequently, on May 12, 1954, she filed a notice of appeal and requested an extension for filing the appeal bond and record on appeal. The appeal bond was filed on May 14, 1954. On May 18, 1954, she filed a second motion for reconsideration and new trial, raising new grounds related to the seizure and sale of mortgaged properties and business assets. The trial court denied this second motion and subsequently dismissed the appeal on June 7, 1954, deeming the decision final. 3. The Petition: The petitioner, Juanita Ronquillo, filed a petition for mandamus with this Court, seeking to compel the respondent judge to elevate the record of appeal to the Court of Appeals. The petitioner argues that the filing of the second motion for reconsideration should have suspended the period for appeal. However, the Court finds that the grounds raised in the second motion were available at the time of the first motion and were therefore deemed waived. The Court also notes that a second motion for new trial based on grounds already existing is generally not permitted and does not stay the period to appeal. The petitioner's appeal record was filed on June 3, 1954, which was beyond the extended deadline of May 30, 1954, leading to the dismissal by the lower court.
Issue(s)
Whether a second motion for reconsideration and new trial, based on grounds that were already available and existing at the time the first motion was filed, has the legal effect of suspending the reglementary period to appeal.
Ruling
The petition for mandamus is denied, with costs against the petitioner.
Ratio Decidendi
On Issue 1: The Supreme Court held that the second motion for new trial did not suspend the period to appeal because it was based on grounds already known to the petitioner at the time she filed her first motion. Citing Rule 37, Section 4, the Court emphasized that all available grounds for a new trial must be presented in a single motion, or they are deemed waived. The Court reasoned that to allow parties to file motions in 'small doses' would lead to the undue prolongation of litigation and trifle with the court's valuable time. Applying the rule from Sawit v. Rodas, the Court noted that a second motion for new trial is only permissible if the ground did not exist when the first motion was made. In this case, since the sheriff's sale occurred on March 15, 1954, the facts were already known before the first motion was filed on April 14, 1954. The Court computed the remaining appeal period and concluded that even with extensions, the deadline to file the Record on Appeal was May 30, 1954. Because the petitioner only filed her Record on Appeal on June 3, 1954, the trial court did not err in declaring the judgment final and dismissing the appeal.
Main Doctrine
A second motion for new trial based on grounds that existed at the time of the first motion is considered a waiver of those grounds and does not suspend the period to appeal. The Rules of Court require all available grounds for a motion to be presented at once to avoid undue delay in the disposition of cases.