Del Rosario v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: On July 13, 1967, a judgment was rendered in the case. Petitioners received a copy on July 28, 1967. Procedural History: On August 22, 1967, petitioners filed a motion for reconsideration. They were granted leave to file a supporting memorandum. On September 2, 1967, they filed supplemental arguments praying for the setting aside of the decision. Respondents filed an opposition on September 2, 1967. On September 8, 1967, the Court denied the reconsideration prayed for in the supplemental arguments. Entry of judgment was made on October 13, 1967. The Petition: On April 23, 1968, petitioners filed another motion for reconsideration, claiming the decision was not in accordance with settled jurisprudence. This was denied on May 3, 1968, due to the prior entry of judgment. On June 27, 1968, petitioners filed yet another motion for reconsideration, claiming no resolution on the basic motion for reconsideration and that the entry of judgment was premature, and that their latest motion was meritorious.
Issue(s)
Whether the petitioners' basic motion for reconsideration was resolved. Whether the entry of judgment was premature and thus null and void. Whether the petitioners' subsequent motions for reconsideration could be considered.
Ruling
The Court denied the petitioners' last motion for reconsideration. The Court found no merit in the contention that the basic motion for reconsideration had not been resolved, as the supplemental arguments filed by the petitioners precisely prayed for the setting aside of the decision, which was denied by the resolution of September 8, 1967. Therefore, the decision had become final and executory when the entry of judgment was made on October 13, 1967. Consequently, the last motion for reconsideration filed on June 27, 1968, could no longer be considered.
Ratio Decidendi
On whether the petitioners' basic motion for reconsideration was resolved: The Court held that the petitioners' basic motion for reconsideration was indeed resolved. The supplemental arguments filed by the petitioners on September 2, 1967, explicitly prayed for the setting aside of the decision promulgated on July 13, 1967. The Court's resolution on September 8, 1967, which denied, among other things, the reconsideration prayed for in these supplemental arguments, constituted a resolution of the basic motion. Therefore, the contention that the motion remained unresolved was without merit. On whether the entry of judgment was premature and thus null and void: The Court found that the entry of judgment made on October 13, 1967, was not premature. This was because the basic motion for reconsideration, along with the supplemental arguments, had been resolved by the Court's resolution on September 8, 1967. Once a motion for reconsideration is denied, the decision becomes final and executory, allowing for the entry of judgment. The petitioners' counsel received notice of this denial on October 6, 1967, well before the entry of judgment. On whether the petitioners' subsequent motions for reconsideration could be considered: The Court ruled that the subsequent motions for reconsideration filed by the petitioners could not be considered. The first subsequent motion, filed on April 23, 1968, was denied because final judgment had already been entered on October 13, 1967. The second subsequent motion, filed on June 27, 1968, was also denied because the decision had become final and executory. The Court reiterated that after entry of judgment, a case becomes final and executory, and further motions for reconsideration are generally not allowed, especially when they raise issues that were already passed upon or could have been raised earlier.
Main Doctrine
A motion for reconsideration, including supplemental arguments, that seeks to set aside a decision is considered resolved when the Court denies it. Subsequent motions for reconsideration after entry of judgment are generally proscribed.