Del Rosario v. Jimenez
REITERATIONFacts
1. The Antecedents: Petitioners Pilar T. del Rosario and Mariano V. del Rosario were defendants in a detainer case filed by respondents Sancho R. Jacinto and Domingo C. Bascara. The respondents sought to recover possession of a parcel of land, along with damages, attorney's fees, and costs. The Municipal Court of Quezon City, presided over by Judge Damian Jimenez, initially ruled in favor of the respondents, ordering the Del Rosarios to vacate the land and pay P200 monthly for its use, plus P500 in attorney's fees. 2. Procedural History: Following the initial decision on July 15, 1963, the respondents filed a motion for amendment and reconsideration on July 24, 1963, seeking an increase in the monthly compensation. The very next day, July 25, 1963, the Del Rosarios filed their notice of appeal. On August 9, 1963, the respondent Judge issued an amended decision, increasing the monthly compensation to P400. Subsequently, the Del Rosarios initiated a new action in the Court of First Instance of Rizal, seeking a writ of certiorari and prohibition to annul the amended decision, arguing the municipal court lost jurisdiction upon their appeal. The Court of First Instance dismissed this petition, leading to the present appeal. 3. The Petition: This case reaches the Supreme Court on appeal from the Court of First Instance of Rizal's order dismissing the petition for certiorari and prohibition. The petitioners argue that the municipal court exceeded its jurisdiction by issuing an amended decision after an appeal had been filed. However, the Supreme Court finds the appeal devoid of merit, asserting that certiorari and prohibition were improper remedies as the amended decision was appealable. Furthermore, the Court notes that the respondents' motion for reconsideration was filed before the original decision became final and before the appeal was lodged, preserving the municipal court's authority to act on the motion.
Issue(s)
Whether the municipal court retained jurisdiction to render an amended decision after a notice of appeal had been filed. Whether a premature appeal divests the court of jurisdiction to act on a pending motion for reconsideration.
Ruling
The Court of Appeals affirmed the order of the Court of First Instance of Rizal, dismissing the petition for certiorari and prohibition. The amended decision was deemed appealable, rendering certiorari and prohibition improper remedies. Furthermore, the motion for reconsideration was filed before the original decision became final and executory and before the appeal was interposed, thus preserving the court's authority to act on the motion.
Ratio Decidendi
On Issue 1: The Court held that the municipal court retained jurisdiction to render an amended decision. This is because the respondents' motion for reconsideration was filed before the original decision became final and executory and before the petitioners' notice of appeal was filed. A timely motion for reconsideration suspends the period for appeal, and the court retains its authority to act upon such motion. Therefore, the amended decision was a valid exercise of the court's power to correct its own judgment before it became final. On Issue 2: The Court ruled that a premature appeal does not divest the court of jurisdiction to act on a pending motion for reconsideration. The petitioners' notice of appeal, filed after the motion for reconsideration but before its resolution, was considered premature. The filing of the motion for reconsideration had the effect of suspending the reglementary period for appeal. Consequently, the court's authority and duty to pass upon the motion for reconsideration remained intact, and its subsequent amended decision was validly issued. The proper remedy against the amended decision would be to appeal it, not to file a petition for certiorari or prohibition.
Main Doctrine
The filing of a motion for reconsideration, when done within the reglementary period, tolls the period for appeal. Consequently, an appeal filed after the motion for reconsideration but before the resolution of said motion is considered premature and does not divest the court of its jurisdiction to act on the motion. The court retains its authority to amend or reconsider its decision until the motion is resolved and the judgment becomes final and executory.