Ortigas v. Velasco
REITERATIONFacts
The Antecedents: The Supreme Court issued a Decision in consolidated cases G.R. No. 109645 and G.R. No. 112564 on July 25, 1994. A Resolution dated January 23, 1995, denied with finality petitioner Dolores V. Molina's motion for reconsideration and its supplements. Despite this, Molina filed a "Motion for Leave to File the Herein Incorporated Second Motion for Reconsideration and to Allow . . Dolores V. Molina a Day in Court Relative to Her Petition for Reconstitution" dated February 27, 1995. A Resolution dated March 1, 1995, reiterated the denial with finality and ordered that "no further pleadings, motions or papers shall he filed . . except only as regards the issues directly involved in the 'Motion for Reconsideration' (Re: Dismissal of Respondent Judge)." Subsequently, on July 24, 1995, another Resolution declared the cases closed and terminated, reiterated the prohibition on further filings, and directed entry of judgment. Procedural History: Private respondent Manila Banking Corporation (Manilabank) filed a motion to cite Dolores V. Molina in contempt of court for allegedly defying lawful orders and eroding the Court's authority. Manilabank asserted that Molina's subsequent filings, including a motion to refer the cases to the Court En Banc (April 5, 1995), a consolidated motion for reconsideration of the denial of the referral (July 25, 1995), and a motion for reconsideration of the July 24, 1995 Resolution (August 21, 1995), were unmeritorious, filed for delay, and barred by previous resolutions. The Petition: Molina opposed the contempt charge, arguing that her pleadings were allowed under the Revised Rules of Court, were meritorious, presented new legal issues, and were filed before she learned of the entry of judgment. She maintained that her pleadings sought only to give her a day in court.
Issue(s)
Whether Dolores V. Molina is guilty of contempt of court for filing multiple motions for reconsideration and other pleadings after the judgment had become final and executory and despite explicit prohibitions against further filings. Whether the subsequent motions filed by Dolores V. Molina were meritorious and presented new legal issues not previously passed upon by the Court. Whether the denial of a motion for reconsideration signifies finality and precludes further pleadings, even if labeled as a "second motion for reconsideration" or seeking "leave of court."
Ruling
The Supreme Court found Dolores V. Molina guilty of contempt of court and imposed a fine of P1,000.00, with a warning against future disobedience.
Ratio Decidendi
On the issue of contempt of court: The Court held that Dolores V. Molina was guilty of contempt of court for willful disregard and disobedience of the Resolutions of the Court. The Court emphasized that litigation must end at some point, and parties cannot be allowed to persist in presenting arguments after they have been pronounced without merit and their motions for reconsideration have been denied. The filing of a second motion for reconsideration is forbidden except for extraordinarily persuasive reasons and upon express leave, which was not obtained by Molina. Her subsequent motions, including the motion to refer the cases to the Court En Banc, were filed in defiance of explicit orders prohibiting further pleadings. The Court reiterated that a denial of a motion for reconsideration signifies finality and that any further arguments or submissions are not to be entertained. Molina's persistent filing of motions, despite clear directives that the cases were closed and terminated and that no further pleadings should be filed, constituted a deliberate disregard and defiance of the Court's plain orders and an abuse of the rules of procedure to delay the termination of the cases. This obstruction of justice is the essence of contempt of court. On the merit of subsequent motions and new legal issues: The Court found that Molina's claim of presenting "new" legal issues was unsubstantiated and that even if they were new, they were waived by failure to assert them at the first opportunity. The Court stressed that the "piece-meal" impugnation of a judgment by successive motions for reconsideration is anathema. The grounds for reconsideration must be set out in the initial motion, and those not included are deemed waived. The Court noted that Molina's second motion for reconsideration, filed without express leave, was mere surplusage and incapable of producing legal effects. The Court also clarified that the denial of a motion for reconsideration means that the grounds relied upon are without merit and that any other grounds not raised are deemed waived. The Court's directive against filing further pleadings was clear and absolute, except for issues directly related to the "Motion for Reconsideration" (Re: Dismissal of Respondent Judge), which Molina's subsequent filings did not pertain to. On the finality of judgments and prohibition against further pleadings: The Court underscored that the denial of a motion for reconsideration, especially when qualified with "with finality," signifies that the Court will entertain no further arguments or submissions. The Court clarified that the En Banc is not an appellate tribunal for decisions of Divisions, and referrals are discretionary. The prohibition against filing further pleadings is a directive that exacts observance, and willful disregard constitutes constructive contempt. The Court stated that the judgment of a division is as authoritative and final as that of the Court En Banc. The Court's resolutions declaring the cases closed and terminated, reiterating the prohibition on further filings, and directing entry of judgment were unequivocal. Molina's continued attempts to reopen proceedings after these directives demonstrated a clear intent to defy the Court's authority and prolong the litigation, thereby obstructing the administration of justice.
Main Doctrine
A party who persistently files motions for reconsideration after a judgment has become final and executory, despite repeated denials and explicit prohibitions against further filings, is guilty of contempt of court for willful disregard and disobedience of court orders, which obstructs the administration of justice.