De Los Reyes v. People
REITERATIONFacts
1. The Antecedents: Petitioners Gilberto M. de los Reyes and Cesar Q. Concon, along with Antonio Callanta, were charged with violating Section 106 in relation to Section 30 of Presidential Decree No. 464 (Property Tax Code). The charge stemmed from their alleged unauthorized reassessment of real properties in Cebu City in 1988, which resulted in a decrease of assessed values without the intervention of the Local Board of Assessment Appeals. The prosecution contended that the petitioners, as public officers, acted illegally by reassessing properties with values exceeding P100,000.00 without proper authority. 2. Procedural History: The case originated with an Information filed in the Municipal Trial Court (MTC) of Cebu City, which convicted De los Reyes and Concon while acquitting Callanta. This conviction was affirmed by the Regional Trial Court (RTC). Subsequently, the petitioners appealed their conviction to the Sandiganbayan (A/R No. 003). Separately, administrative charges led to a suspension for one year, and criminal charges under R.A. No. 3019 were filed, resulting in an acquittal for all accused. The Sandiganbayan, in A/R No. 003, affirmed the RTC's decision on July 7, 2004. A motion for reconsideration was filed by the petitioners, but the Sandiganbayan declared it a mere scrap of paper on August 12, 2004, deeming its decision final and executory. 3. The Petition: The petitioners filed a petition for review with the Supreme Court, assailing the Sandiganbayan's Resolution of August 12, 2004. They argued that their motion for reconsideration was improperly declared a mere scrap of paper, as it was not required to be set for hearing under the applicable rules for appealed cases before the Sandiganbayan. They contended that service of the motion on the Special Prosecutor was sufficient. Furthermore, they argued that even if a hearing was required, the interest of justice warranted relaxation of the rules, citing previous Supreme Court decisions. They also raised the issue that the Sandiganbayan's judgment was contrary to the Supreme Court's findings in the administrative aspect of the case.
Issue(s)
Whether the Sandiganbayan erred in declaring petitioners' motion for reconsideration a mere scrap of paper due to failure to set it for hearing. Whether the Sandiganbayan erred in taking a contrary judgment to the Supreme Court's findings in the administrative case. Whether the Sandiganbayan committed grave abuse of discretion in failing to consider other facets and ratiocinations of the RTC's decision.
Ruling
The petition is meritorious. The August 12, 2004 Resolution of the Sandiganbayan is NULLIFIED. The Sandiganbayan is DIRECTED to resolve Petitioners’ motion for reconsideration of its decision in A/R No. 003 in due course.
Ratio Decidendi
On the procedural issue of the motion for reconsideration: The Sandiganbayan erred in declaring the petitioners' motion for reconsideration a mere scrap of paper. The Sandiganbayan failed to cite any rule for this declaration. Under the second paragraph of Section 2, Rule 1, Part 1 of the 2002 Revised Internal Rules of the Sandiganbayan, the Rules of Court apply to proceedings before the Sandiganbayan in the absence of a specific provision. In appealed cases, Section 1, Rule VII of the Sandiganbayan's Revised Internal Rules mandates the application of Section 3, Rule 49 of the 1997 Rules of Civil Procedure. Section 3 of Rule 49 explicitly states that "Motions shall not be set for hearing and, unless the court otherwise directs, no hearing or oral argument shall be allowed in support thereof." The adverse party is given five days to file objections. Therefore, petitioners were not obliged to set their motion for hearing; they were only required to serve a copy on the Special Prosecutor. The Sandiganbayan's perfunctory denial of the motion and declaration of finality was contrary to its own rules, rendering the resolution a nullity. On the substantive issue of guilt (implied): While the primary issue addressed was procedural, the Court's action in directing the Sandiganbayan to resolve the motion for reconsideration implies that the substantive issues raised by the petitioners regarding their guilt or innocence, and the alleged contrary judgment to the administrative case, were not yet definitively resolved and would be subject to further review. The Court noted that the administrative case found petitioners not to have acted willfully or through gross negligence, which could be a significant factor in the substantive review of the criminal case. The Court's decision to grant the petition and order the resolution of the motion for reconsideration indicates that the Sandiganbayan's procedural error prevented a full and proper consideration of the merits of the case, including the petitioners' defense and the potential inconsistency with prior findings. On the issue of grave abuse of discretion: The Sandiganbayan's procedural misstep in treating the motion for reconsideration as a scrap of paper, without proper legal basis and contrary to its own rules and applicable provisions of the Rules of Civil Procedure, constitutes a grave abuse of discretion. This procedural error prevented the proper adjudication of the case on its merits. The Court found that the Sandiganbayan "acted contrary to its own rules" and that the "assailed resolution of the Sandiganbayan is a nullity." This indicates a clear disregard for established legal procedures, which is a hallmark of grave abuse of discretion. The failure to consider "other facets and pertinent ratiocinations" of the lower appellate court's decision, as alleged by the petitioners, would also fall under this category if the procedural error prevented such consideration.
Main Doctrine
A motion for reconsideration of a Sandiganbayan decision, when filed in appealed cases, is governed by Section 3, Rule 49 of the 1997 Rules of Civil Procedure, which does not require the motion to be set for hearing. Failure to set the motion for hearing does not render it a mere scrap of paper, and the period to appeal is tolled.