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VALENCIA FARMERS COOPERATIVE v. HEIRS OF CABOTAJE

FACTS:

Petitioner Valencia (Bukidnon) Farmers Cooperative Marketing Association, Inc. (FACOMA) filed an action for quieting of title and recovery of ownership and possession of a parcel of land against respondents Heirs of Amante P. Cabotaje. The Regional Trial Court (RTC) ruled in favor of FACOMA, ordering the annulment and cancellation of the Deed of Sale and the transfer certificates of title issued pursuant thereto, and ordering the respondents to vacate the property and demolish their improvements. Respondents filed a Motion for Reconsideration, but the RTC denied it. Subsequently, the respondents filed a Notice of Appeal, but FACOMA moved to dismiss it, claiming that the Motion for Reconsideration did not toll the reglementary period to appeal. The RTC denied the Notice of Appeal for being filed out of time. The respondents then filed a Petition for Certiorari with the Court of Appeals (CA) to challenge the denial of the Notice of Appeal. Meanwhile, FACOMA filed a Motion for Execution of Judgment, which was initially denied by the RTC but eventually granted. The CA granted the Petition for Certiorari, setting aside the RTC’s denial of the Notice of Appeal and ordering the RTC to give due course to the appeal. FACOMA filed a Petition for Review on Certiorari assailing the CA’s decision.

ISSUES:

  1. Whether the Certiorari Petition assailed the RTC's Resolution dated April 4, 2011 or the Decision dated December 3, 2010.

  2. Whether the respondents Heirs of Cabotaje's Motion for Reconsideration is a pro forma motion.

  3. Whether the motion for reconsideration filed by respondents was pro forma and therefore did not toll the reglementary period to file an appeal.

  4. Whether the execution of the trial court's judgment rendered the case moot and academic.

RULING:

  1. The Certiorari Petition filed by respondents Heirs of Cabotaje assailed the RTC's Resolution dated April 4, 2011. The Court finds no reason to reverse the factual finding of the CA on this matter.

  2. The Motion for Reconsideration filed by respondents Heirs of Cabotaje is not a pro forma motion. The Court has held that the mere reiteration of the issues raised by the parties in a motion for reconsideration does not make it pro forma. The respondents' motion complied with the requirements and substantiated the alleged errors in the RTC's Decision.

  3. The Court held that the motion for reconsideration was not pro forma. The Court upheld the finding of the CA that the motion raised an issue that was not discussed in the prior decision, thus showing that it was not a mere reiteration of arguments previously rejected. Therefore, the motion for reconsideration was valid and tolled the reglementary period to file an appeal.

  4. The Court held that the execution of the trial court's judgment did not render the case moot and academic. The Court explained that the Rules of Court provide for restitution or reparation in case a judgment is reversed on appeal. Therefore, the appeal filed by respondents was not futile, and there was still a practical use and value in resolving the case.

PRINCIPLES:

  • The Court is not a trier of facts and is bound by the factual findings of the CA when supported by substantial evidence.

  • Grave abuse of discretion arises when a lower court or tribunal patently violates the Constitution, the law, or existing jurisprudence.

  • A motion for reconsideration is not pro forma just because it reiterates the issues raised by the parties in the case.

  • The respondents' Motion for Reconsideration must comply with the requirements and substantiate the alleged errors in the lower court's decision.

  • A motion for reconsideration is not pro forma if it raises new issues or arguments that were not previously discussed and rejected by the court.

  • The execution of a judgment does not automatically render a case moot and academic. The Rules of Court provide for restitution or reparation in case the judgment is reversed on appeal.

  • An issue on jurisdiction prevents a petition from becoming moot and academic, despite the execution of the lower court's judgment.