Valencia Farmers Cooperative v. Heirs of Cabotaje
REITERATIONFacts
The Antecedents: Petitioner Valencia (Bukidnon) Farmers Cooperative Marketing Association, Inc. (FACOMA) initiated an action against the Heirs of Amante P. Cabotaje and Francisco Estrada, seeking to quiet title and recover ownership and possession of a parcel of land, along with damages. The Regional Trial Court (RTC) ruled in favor of FACOMA, annulling a Deed of Sale executed by Francisco Estrada in favor of Amante Cabotaje and canceling the Transfer Certificates of Title issued pursuant to that sale. The RTC also ordered the defendants to vacate the property and for any improvements made in bad faith to be demolished. Procedural History: Following the RTC's decision, the Heirs of Amante P. Cabotaje filed a Motion for Reconsideration, primarily arguing FACOMA's lack of legal personality to sue, the validity of the Deed of Sale, and the binding nature of the sale to them. The RTC denied this motion, deeming it pro forma, and subsequently denied the Heirs' Notice of Appeal as filed out of time. Aggrieved, the Heirs of Cabotaje filed a Petition for Certiorari with the Court of Appeals (CA). During the pendency of the CA petition, FACOMA filed a Motion for Execution of Judgment, which the RTC eventually granted. The Petition: The Court of Appeals granted the Heirs of Cabotaje's Petition for Certiorari, setting aside the RTC's resolution denying their Notice of Appeal and ordering the RTC to give due course to the appeal. The CA found that the Heirs' Motion for Reconsideration was not pro forma and thus tolled the reglementary period for appeal. The CA also held that the execution of the RTC's judgment did not render the case moot and academic, as restitution could be ordered if the appeal prospered. Petitioner FACOMA, represented by its Board Chairman David M. Porticos, now seeks review of the CA's decision and resolution through a Petition for Review on Certiorari under Rule 45 of the Rules of Court, arguing that the CA erred in its findings regarding the nature of the motion for reconsideration, the denial of the appeal, and the mootness of the case due to the execution of judgment.
Issue(s)
Whether the CA erred in holding that the certiorari petition assailed the RTC's Resolution dated April 4, 2011, and not the RTC's Decision dated December 3, 2010. Whether the CA erred in holding that the Notice of Appeal filed by the respondents Heirs of Cabotaje was wrongfully denied by the RTC, considering that their Motion for Reconsideration was not a pro forma motion. Whether the CA erred in failing to declare the certiorari petition moot and academic, considering that the RTC had granted petitioner FACOMA's Motion for Execution of Judgment during the pendency of the certiorari petition.
Ruling
The Supreme Court denied the Petition for Review on Certiorari, affirming the Decision and Resolution of the Court of Appeals. The Court held that the CA correctly found that the certiorari petition assailed the RTC's Resolution denying the Notice of Appeal, that the respondents' Motion for Reconsideration was not pro forma, and that the case was not rendered moot and academic by the execution of the RTC's judgment.
Ratio Decidendi
On the first issue: The Court found petitioner FACOMA's submission unmeritorious. The CA correctly found as a fact that the certiorari petition filed by respondents Heirs of Cabotaje was centered on the RTC's Resolution dated April 4, 2011, which denied their Notice of Appeal due to their Motion for Reconsideration supposedly being pro forma. The Court reiterated that it is not a trier of facts and that the findings of the CA, when supported by substantial evidence, are conclusive. A perusal of the certiorari petition clearly showed that respondents alleged grave abuse of discretion by the RTC in issuing its Resolution dated April 4, 2011, and that this was their sole remedy. On the second issue: The Court found petitioner FACOMA's second submission without merit. Grave abuse of discretion arises when a lower court patently violates the Constitution, law, or jurisprudence. The RTC deemed the respondents' Motion for Reconsideration pro forma for not raising new arguments. However, the Court has consistently held that the mere reiteration of issues in a motion for reconsideration does not make it pro forma. The Court cited jurisprudence establishing that a motion for reconsideration is not pro forma if it aims to convince the court that its ruling was erroneous, contrary to law or evidence. Furthermore, the CA correctly noted that the respondents' Motion for Reconsideration stressed the issue of petitioner FACOMA's legal capacity to sue, which was not discussed in the RTC's Decision, thus demonstrating it was not pro forma. On the third issue: The Court found petitioner FACOMA's theory that the execution of the RTC's Decision rendered the case moot and academic to be without merit. A case becomes moot and academic only when it ceases to present a justiciable controversy due to supervening events, rendering adjudication useless. However, the Rules of Court provide for situations where an executed judgment may be reversed on appeal, allowing for restitution or reparation of damages under Rule 39, Section 5. Therefore, the execution of the judgment does not bar the continuance of the appeal, as there is still a possibility of reversal and subsequent restitution. The Court also noted that an issue on jurisdiction, as alleged in a certiorari petition, prevents the case from becoming moot and academic despite the execution of the lower court's judgment.
Main Doctrine
A motion for reconsideration is not pro forma merely because it reiterates issues previously passed upon, especially if it raises arguments to convince the court that its ruling was erroneous. The filing of a motion for reconsideration that is not pro forma tolls the reglementary period to appeal. Furthermore, the execution of a judgment does not render an appeal moot and academic, as restitution may be ordered if the executed judgment is reversed on appeal.