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MARIKINA VALLEY DEVELOPMENT CORPORATION v. NAPOLEON R. FLOJO

FACTS:

Jose Reyes Sytangco filed a complaint for reconveyance of a piece of land in Manila against Marikina Valley Development Corporation ("Marikina Valley") and Milagros Liamzon. He alleged that he and his wife entrusted funds to Milagros Liamzon to purchase the land, but she bought it in her own name and transferred the title to Marikina Valley. Marikina Valley denied the allegations and claimed that Milagros Liamzon used funds from the corporation to purchase the property. Milagros Liamzon argued that the Sytangco spouses had waived their right to buy the property. After Jose Reyes Sytangco died, his heirs were substituted as plaintiffs. The trial court ruled in favor of the heirs and directed Marikina Valley to execute a Deed of Conveyance. Petitioners moved for reconsideration, but the trial court denied their motion.

Petitioners filed a notice of appeal, but it was dismissed by the trial court. The Court of Appeals affirmed the dismissal, stating that the motion for reconsideration was pro forma and did not interrupt the running of the appeal period. Petitioners filed a Petition for Review on Certiorari before the Supreme Court, arguing that their motion for reconsideration was sufficient and that their appeal was filed on time.

The issue in this case is whether a motion for reconsideration is considered pro forma when it merely reiterates or repleads the same arguments previously considered and resolved in the decision sought to be reconsidered. The Court of Appeals took the position that such a motion is pro forma and will not interrupt the running of the period to perfect an appeal. However, it was noted that a motion for reconsideration dealing with the same issues raised and resolved by the trial court does not necessarily mean that it is pro forma. Justice J.B.L. Reyes had previously pointed out that a motion for reconsideration must necessarily address the arguments made or accepted by the trial court in its decision.

ISSUES:

  1. Whether a motion for reconsideration must address the arguments made or accepted by the trial court in its decision.

  2. What constitutes a pro forma motion for reconsideration.

  3. Whether the second motion for reconsideration is allowed based on grounds already existing at the time the first motion for reconsideration was filed.

  4. Whether the period to appeal had already lapsed at the time the second motion for reconsideration was filed.

  5. Whether or not the doctrine relating to pro forma motions for reconsideration should be applied reasonably instead of literally.

  6. Whether or not the right to appeal should be accorded an effective opportunity for review rather than being aborted by a literal application of the procedural rule.

RULING:

  1. Yes, a motion for reconsideration must address the arguments made or accepted by the trial court in its decision. The purpose of a motion for reconsideration is to convince the court that its ruling is erroneous and improper, contrary to the law or the evidence. In failing to discuss the issues passed upon by the court, the remedy would be a new trial or some other remedy, not a reconsideration.

  2. A motion for reconsideration that fails to specify the findings or conclusions in the trial court's decision that are supposedly not supported by evidence or contrary to law is considered a pro forma motion. Similarly, a motion for reconsideration that merely alleges that the order is contrary to law and the facts of the case is also considered as pro forma. A motion for reconsideration is not pro forma if it sufficiently explains where and why the trial court erred in its main decision.

  3. The Court dismissed the case for having been appealed beyond the reglementary period.

  4. The Court reversed and set aside the Orders of the trial court and the Decision of the Court of Appeals. The case is remanded to the trial court and directed to give due course to petitioners' notice of appeal.

  5. No pronouncement as to costs.

PRINCIPLES:

  • A motion for reconsideration must address the arguments made or accepted by the trial court in its decision.

  • A pro forma motion for reconsideration fails to specify the findings or conclusions in the trial court's decision that are supposedly not supported by evidence or contrary to law.

  • A pro forma motion for reconsideration is intended to delay or impede the progress of proceedings and does not stop the period of appeal from running.

  • A motion for reconsideration that is not pro forma is one that makes a substantial bona fide effort to explain where and why the trial court erred in its main decision.

  • The filing of a motion for reconsideration within the reglementary period does not necessarily mean it is not a delaying tactic, but it may be considered a factor in determining the intent of the movant.

  • The filing of a second motion for reconsideration based on grounds already existing at the time the first motion for reconsideration was filed is not allowed.

  • The period to appeal should not have already lapsed at the time the second motion for reconsideration is filed.

  • The right to appeal, where it exists, is an important and valuable right.

  • The doctrine relating to pro forma motions for reconsideration should be applied reasonably, rather than literally, as it impacts upon the reality and substance of the statutory right of appeal.