Acampado v. Cosmilla
REITERATIONFacts
1. The Antecedents: Respondents Spouses Lourdes and Felimon Cosmilla filed a case against petitioners seeking the declaration of nullity of a document, alleging that the sale of their share in a property was effected through a forged Special Power of Attorney (SPA) and was therefore void. The Regional Trial Court (RTC) dismissed the complaint, finding that the respondents failed to prove by a preponderance of evidence that the signatures on the SPA were forged. The RTC also ordered the respondents to pay attorney's fees and litigation expenses to the petitioners. 2. Procedural History: Aggrieved by the RTC's decision, the respondents filed a Motion for Reconsideration. However, the RTC denied this motion, deeming it pro forma for failing to comply with the required notice of hearing under the Rules of Court. The respondents then filed a Petition for Certiorari, Prohibition, and Mandamus with the Court of Appeals (CA), seeking to annul the RTC's order denying their motion for reconsideration. Initially, the CA dismissed the petition, agreeing that the motion for reconsideration was fatally defective. However, upon the respondents' Motion for Reconsideration, the CA reversed its earlier decision, allowing for the relaxation of procedural rules and directing the RTC to resolve the motion on its merits. The petitioners' subsequent Motion for Reconsideration of the CA's resolution was denied. 3. The Petition: The petitioners are now before the Supreme Court via a Petition for Review on Certiorari under Rule 45 of the Rules of Court. They seek to reverse and set aside the CA's resolutions dated June 28, 2007, and August 19, 2011. The petitioners argue that the CA gravely erred in reconsidering its own decision that dismissed the respondents' petition for certiorari, prohibition, and mandamus, thereby effectively reinstating a motion for reconsideration that was pro forma and had failed to comply with mandatory procedural requirements for notice and hearing, which are essential for due process.
Issue(s)
Whether the Court of Appeals gravely erred in reversing its own decision and allowing the resolution of the respondents' motion for reconsideration on the merits despite its pro forma nature. Whether the RTC's denial of the respondents' motion for reconsideration for failure to comply with the notice of hearing requirements was proper.
Ruling
The Supreme Court granted the petition, reversed and set aside the assailed Resolutions of the Court of Appeals, and reinstated the Decision of the Regional Trial Court dismissing the respondents' complaint and its Order declaring their Motion for Reconsideration as pro forma.
Ratio Decidendi
On the Court of Appeals' reversal of its own decision: The Court found that the Court of Appeals gravely erred in reversing its own decision that correctly dismissed the petition for certiorari. By allowing the respondents' pro forma motion for reconsideration to be resolved on the merits, the CA effectively disregarded the mandatory rules of procedure and the principle that a judgment becomes final and executory if no appeal is filed within the reglementary period. The Court stressed that every litigation must come to an end once a judgment becomes final, executory, and unappealable. To allow dilatory schemes would frustrate the efforts of the courts and the winning party's right to enjoy the finality of the resolution of their case. Therefore, the RTC's denial of the motion for reconsideration was proper, and the CA's subsequent resolutions were erroneous. On the propriety of the RTC's denial of the respondents' motion for reconsideration: The Court reiterated that a motion for reconsideration is a contentious motion that must comply with the required notice and hearing and service to the adverse party as mandated by Sections 4, 5, and 6 of Rule 15 of the Revised Rules of Court. These requirements are mandatory, and failure to religiously comply renders the motion pro forma. A pro forma motion is a worthless piece of paper that the clerk of court has no right to receive and the court has no authority to act upon. The notice of hearing is a form of due process, giving the adverse party an opportunity to oppose the motion. Failure to comply with the required notice and hearing is a fatal defect that is deleterious to the movant's cause. The Court emphasized that the absence of proof of service and notice to the adverse party is fatal to the motion, rendering it not entitled to judicial cognizance. Consequently, the RTC correctly denied the respondents' motion for reconsideration.
Main Doctrine
A motion for reconsideration that fails to comply with the mandatory requirements of notice of hearing and proof of service, as mandated by Sections 4, 5, and 6 of Rule 15 of the Revised Rules of Court, is considered pro forma, fatally defective, and does not toll the reglementary period for appeal, rendering the judgment final and executory.