Philippine Advertising Counselors v. Revilla
REITERATIONFacts
The Antecedents: Petitioner Philippine Advertising Counselors, Inc. (PAC) sued respondent Southern Industrial Projects, Inc. (SIP) for an unpaid account totaling P97,952.08 for advertising and promotional services rendered from July 1, 1962, to November 1, 1963. SIP, through its lawyer, admitted the indebtedness in writing, acknowledging the amount and proposing a payment plan via amortization due to financial difficulties. Partial payments were made, reducing the outstanding balance to P89,100.03 as of December 31, 1967. Despite repeated demands, SIP failed to make further payments, prompting PAC to file a collection suit, also seeking attorney's fees. Procedural History: PAC filed a complaint against SIP with the Court of First Instance of Rizal. SIP moved for a bill of particulars, which was denied. SIP then filed an answer, which PAC argued failed to tender an issue. PAC moved for judgment on the pleadings, but the trial court initially denied it. After a failed pre-trial and a trial where SIP did not appear, the court reconsidered its ruling, finding SIP's answer insufficient and deeming the allegations admitted, ordering SIP to pay PAC P89,100.03 plus interest and attorney's fees. SIP moved for reconsideration, arguing its answer was a specific denial and that it had filed a memorandum. The trial court granted this motion, setting aside its decision and scheduling a hearing on the merits. PAC moved for reconsideration and execution, arguing the first motion for reconsideration was pro forma and did not interrupt the appeal period. This motion was denied. PAC then filed a petition for certiorari, prohibition, and mandamus with the Court of Appeals, which dismissed the petition and dissolved a preliminary injunction. PAC's subsequent motion for reconsideration was denied, leading to the present appeal. The Petition: Petitioner PAC seeks review of the Court of Appeals' decision, arguing that the trial court gravely abused its discretion in granting SIP's motion for reconsideration and setting aside its earlier decision. PAC contends that SIP's motion for reconsideration was pro forma because it failed to specifically state the findings or conclusions contrary to law and did not set a definite hearing date. PAC further argues that SIP's answer, which denied allegations for lack of sufficient knowledge or information, was insufficient to raise an issue, especially given the written admissions of indebtedness by SIP through its counsel. PAC asserts that SIP's failure to oppose the motion for judgment on the pleadings and the lack of a valid appeal period interruption due to the pro forma motion for reconsideration meant the judgment should have become final and executory.
Issue(s)
Whether the respondent Court of Appeals committed grave abuse of discretion in affirming the trial court's order granting private respondent's motion for reconsideration, setting aside its decision, and re-setting the case for hearing on the merits. Whether private respondent's motion for reconsideration was pro forma, thus failing to interrupt the period for appeal and rendering the original decision final and executory.
Ruling
The Supreme Court reversed and set aside the appealed judgment of the Court of Appeals. It ordered respondent Southern Industrial Projects, Inc. to pay petitioner Philippine Advertising Counselors, Inc. the amount of P89,100.03, with legal interest thereon from July 20, 1965, until fully paid, plus 10% of the principal amount as attorney's fees, and costs.
Ratio Decidendi
On Issue 1 (Grave Abuse of Discretion in Granting Motion for Reconsideration): The Supreme Court found that the trial court committed grave abuse of discretion in granting the motion for reconsideration. The Court reiterated that a motion for reconsideration must specifically point out the findings or conclusions in the decision that are contrary to law or evidence and explain in detail why they are so. Private respondent's motion merely stated that the decision was contrary to Rule 8, Section 10 of the Rules of Court, without elaborating on how the decision violated this provision. Furthermore, the motion failed to comply with the notice requirements under Rule 15, Sections 4 and 5, by not setting a definite date and time for the hearing and by not providing proof of service to the petitioner. The Court held that a motion failing to meet these requirements is a 'useless piece of paper' and that the duty to provide notice rests with the movant, not the court. Therefore, the filing of such a motion did not suspend the running of the period to perfect an appeal. On Issue 2 (Pro Forma Nature of the Motion for Reconsideration): The Supreme Court held that private respondent's motion for reconsideration was indeed pro forma. The Court explained that the disallowance of pro forma motions is primarily to prevent delay. It cited jurisprudence stating that it is not enough for a motion to state what part of the decision is contrary to law or evidence, but it must also point out why it is so. Private respondent's motion did not meet this standard. Moreover, the motion's failure to set a definite date for hearing and the lack of proof of service on the petitioner rendered it defective. The Court concluded that because the motion was pro forma, it did not interrupt the reglementary period for appeal. Consequently, the trial court's decision of February 18, 1969, had become final and executory, and the trial court exceeded its jurisdiction in granting the motion for reconsideration and setting aside its own judgment.
Main Doctrine
The Supreme Court reiterated that a denial for lack of sufficient knowledge or information to form a belief is a valid denial under Rule 8, Section 10 of the Rules of Court, placing the allegations in issue. However, this denial is insufficient and considered evasive if the matter asserted is plainly and necessarily within the defendant's knowledge. The Court also emphasized that a motion for reconsideration must specifically point out the findings or conclusions contrary to law or evidence and explain why they are so, otherwise, it is considered pro forma and does not interrupt the period for appeal. Additionally, motions must strictly comply with notice requirements, including stating the time and place of hearing, with the movant responsible for providing such notice.