Motion for Reconsideration Must Be Resolved: Sandiganbayan Decision Not Final Until Proper Ruling

TLDR; This case clarifies that a Sandiganbayan decision is not final if a motion for reconsideration is filed, even if the motion wasn’t formally set for hearing, as the Sandiganbayan’s rules at the time did not require it. Proper procedure must be followed before a decision becomes final and executory, and failure to adhere to its own rules renders the Sandiganbayan’s resolution null and void.

G.R. NO. 165341, February 27, 2006, GILBERTO M. DE LOS REYES AND CESAR Q. CONCON, PETITIONERS, VS. THE HONORABLE SANDIGANBAYAN AND PEOPLE OF THE PHILIPPINES, RESPONDENTS.

INTRODUCTION

Imagine receiving a court decision against you. You file a motion for reconsideration, believing you have valid grounds for the court to review its judgment. But then, you are told your motion is disregarded, simply a “scrap of paper,” because you didn’t set it for a hearing, even if the court rules didn’t explicitly require it. This situation highlights a critical aspect of the legal process: the finality of judgments and the proper procedure for motions for reconsideration. The case of De los Reyes v. Sandiganbayan underscores the importance of adhering to procedural rules and ensuring that motions for reconsideration are properly considered before a court decision becomes final. At the heart of this case is a question of procedural fairness: can a court declare its decision final and executory when it has not properly addressed a motion for reconsideration filed by the losing party? The Supreme Court in this case emphatically said no.

LEGAL CONTEXT: FINALITY OF JUDGMENTS AND MOTIONS FOR RECONSIDERATION

In the Philippine legal system, a judgment becomes “final and executory” once the period to appeal has lapsed, and no appeal has been perfected. This finality is crucial because it brings closure to legal disputes. However, the rules of procedure provide mechanisms to challenge a decision before it becomes final, one of which is filing a motion for reconsideration. A motion for reconsideration is a pleading filed by a party asking the court to re-examine the judgment or final order and set aside or reverse it. It essentially gives the court a second chance to correct any errors it might have committed.

The procedural rules governing motions for reconsideration are essential to ensure fairness and due process. Crucially, the Rules of Court differentiate procedures depending on the court level and the nature of the case. In this case, the Sandiganbayan, a special court focused on graft and corruption cases involving public officials, is involved. The Sandiganbayan has its own Revised Internal Rules. These rules, however, are not entirely independent of the Rules of Court. Section 2, Rule 1, Part 1 of the Sandiganbayan’s Revised Internal Rules states, “the Rules of Court, resolutions, circulars and other issuances promulgated by the Supreme Court relating to or affecting the Regional Trial Courts and the Court of Appeals, insofar as applicable, shall govern all actions and proceedings filed with the Sandiganbayan.” This means that in the absence of specific Sandiganbayan rules, the Rules of Court apply.

The core issue in De los Reyes revolves around whether motions for reconsideration in appealed cases before the Sandiganbayan require a formal hearing. The Sandiganbayan, in dismissing the petitioner’s motion, implied that setting the motion for hearing was mandatory. However, the Supreme Court pointed out the flaw in this reasoning by referring to the Sandiganbayan’s own rules. The Sandiganbayan’s Revised Internal Rules, specifically the last paragraph of Section 1, Rule VII, adopts Section 3, Rule 49 of the 1997 Rules of Civil Procedure for motions in appealed cases. Section 3 of Rule 49 explicitly states:

“SEC. 3. No hearing or oral argument for motions. – 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 may file objections to the motion within five (5) days from service, upon the expiration of which such motion shall be deemed submitted for resolution.”

This rule clearly indicates that, unless the court directs otherwise, motions in appealed cases are resolved without a hearing. The Sandiganbayan’s reliance on the requirement of setting a motion for hearing was therefore misplaced and contrary to the very rules it was bound to follow.

CASE BREAKDOWN: THE PROCEDURAL JOURNEY

The case began with an Information filed in the Municipal Trial Court (MTC) of Cebu City against Gilberto de los Reyes and Cesar Q. Concon, along with another accused, for violating Section 106 of the Property Tax Code in relation to Section 30. They were accused of reassessing property values without authority from the Local Board of Assessment Appeals.

Here’s a step-by-step breakdown of the case’s procedural journey:

1. MTC Conviction: The MTC of Cebu City convicted De los Reyes and Concon.
2. RTC Affirmation: On appeal, the Regional Trial Court (RTC) affirmed the MTC’s decision.
3. Sandiganbayan Appeal: De los Reyes and Concon further appealed to the Sandiganbayan.
4. Sandiganbayan Decision: The Sandiganbayan affirmed the RTC’s decision, upholding their conviction.
5. Motion for Reconsideration: Petitioners filed a Motion for Reconsideration of the Sandiganbayan’s decision.
6. Sandiganbayan Dismissal: The Sandiganbayan dismissed the Motion for Reconsideration, declaring it a “mere scrap of paper” because it was not set for hearing and that its decision had become final and executory.
7. Supreme Court Petition: De los Reyes and Concon then filed a Petition for Review with the Supreme Court, arguing that the Sandiganbayan erred in dismissing their motion.

The Supreme Court, in reviewing the Sandiganbayan’s actions, focused on the procedural propriety of dismissing the Motion for Reconsideration. The Court emphasized that the Sandiganbayan’s own rules, incorporating Rule 49, Section 3 of the Rules of Civil Procedure, did not mandate setting motions for hearing in appealed cases. The Supreme Court stated:

“As gleaned from the foregoing provisions, petitioners were not obliged to set for hearing their motion for reconsideration of the Sandiganbayan decision. Petitioners, as movants, were obliged merely to serve a copy of their motion for reconsideration on the Special Prosecutor, who is then given a period of five (5) days from said service within which to file his objections thereto. Such motion shall be deemed submitted for resolution without any further arguments from the parties.”

The Supreme Court further noted the Sandiganbayan’s failure to cite any rule justifying its dismissal of the motion. Because the Sandiganbayan acted contrary to its own rules and applicable procedure, the Supreme Court concluded:

“Thus, in perfunctorily denying petitioners’ motion for reconsideration of its decision and declared that such decision was final and executory, the Sandiganbayan acted contrary to its own rules. Patently then, the assailed resolution of the Sandiganbayan is a nullity.”

Ultimately, the Supreme Court granted the petition, nullified the Sandiganbayan’s resolution, and directed the Sandiganbayan to resolve the Motion for Reconsideration on its merits.

PRACTICAL IMPLICATIONS: PROCEDURAL DUE PROCESS MATTERS

The De los Reyes v. Sandiganbayan case serves as a stark reminder that procedural due process is just as crucial as substantive law. Even if a court might have the power to decide a case in a certain way, it must exercise that power within the bounds of established rules of procedure. This case highlights several practical implications for litigants, especially those involved in cases before the Sandiganbayan or other appellate courts:

• Know the Rules: Litigants and their lawyers must be intimately familiar with the specific rules of procedure of the court they are dealing with. This includes not just the Rules of Court but also internal rules of special courts like the Sandiganbayan.
• Motions in Appealed Cases: In appellate courts, particularly in the Sandiganbayan, motions for reconsideration in appealed cases generally do not require a formal hearing unless the court explicitly directs one. Parties should not assume that they need to set motions for hearing in such instances.
• Proper Service is Key: While hearings might not be required, proper service of the motion on the adverse party is still mandatory. This ensures that the opposing side is given the opportunity to respond and file objections.
• Challenge Procedural Errors: If a court deviates from its own procedural rules to the detriment of a party, this can be a valid ground for appeal or certiorari to a higher court. The Supreme Court’s decision in De los Reyes underscores its willingness to correct procedural missteps by lower courts.

Key Lessons

• Motions for Reconsideration in Sandiganbayan Appeals: Generally, no hearing is required unless directed by the court.
• Importance of Court Rules: Always verify the specific rules of procedure of the court where your case is pending.
• Procedural Due Process: Courts must adhere to their own rules; failure to do so can invalidate their actions.

FREQUENTLY ASKED QUESTIONS (FAQs)

Q: What is a Motion for Reconsideration?

A: A Motion for Reconsideration is a formal request to a court to re-examine its decision. It asks the court to reconsider its judgment, pointing out errors of law or fact, or newly discovered evidence, and to reverse or modify its original ruling.

Q: When is a court decision considered final and executory?

A: A court decision becomes final and executory when the period to appeal has lapsed (typically 15 days from receipt of the decision), and no appeal has been filed. Once final, the decision can be enforced.

Q: What are the rules for filing motions in the Sandiganbayan?

A: The Sandiganbayan follows its Revised Internal Rules. For motions in appealed cases, it applies Section 3, Rule 49 of the Rules of Civil Procedure, which generally does not require hearings for motions unless the court orders otherwise.

Q: What happens if a court incorrectly dismisses my Motion for Reconsideration?

A: If a court improperly dismisses your Motion for Reconsideration by not following its own rules, as in the De los Reyes case, you can file a petition for certiorari with a higher court (like the Supreme Court) to challenge the dismissal and compel the lower court to properly consider your motion.

Q: Where can I find the rules of procedure for the Sandiganbayan?

A: The Revised Internal Rules of the Sandiganbayan are publicly available and can usually be found on the Sandiganbayan’s official website or through legal research databases. You can also request a copy from the Sandiganbayan Clerk of Court.

Q: Does this Supreme Court ruling mean De los Reyes and Concon were acquitted?

A: No, this ruling did not acquit them. It only corrected a procedural error by the Sandiganbayan. The Supreme Court directed the Sandiganbayan to properly resolve De los Reyes and Concon’s Motion for Reconsideration on its merits. The Sandiganbayan still needed to decide whether to grant or deny the motion based on the substantive arguments raised in it.

Q: How can ASG Law help with cases before the Sandiganbayan?

A: ASG Law specializes in litigation and has extensive experience in handling cases before various courts, including the Sandiganbayan. Our team of experienced lawyers can provide expert legal advice, represent you in court, and ensure that your rights are protected throughout the legal process. We are adept at navigating complex procedural rules and crafting compelling legal arguments. Contact us or email hello@asglawpartners.com to schedule a consultation.