SPS. EDMUND CO AND LILY CO AND EDUARDO RAYO, PETITIONERS, VS. HON. JUDGE RITA BASCOS-SARABIA, SHERIFF ADOLFO P. GARCIA, JR. AND METROPOLITAN BANK AND TRUST COMPANY, RESPONDENTS.

Co versus Bascos-Sarabia

The Case

This is the case of Co versus Bascos-Sarabia, a special civil action that reached the Supreme Court as a challenge to the acts of a trial court judge and a sheriff in the enforcement of a judgment in favor of a bank. Spouses Edmund Co and Lily Co, together with Eduardo Rayo, are the petitioners; the respondents are Judge Rita Bascos-Sarabia, Sheriff Adolfo Garcia, Junior, and Metropolitan Bank and Trust Company. The case matters to a reviewee because it fixes the procedural boundaries of the remedy of certiorari against interlocutory orders and the writs of execution that follow them, and because it teaches how strictly the Supreme Court guards the finality of its own decisions.

Procedural History

The dispute began in the trial court, where Metropolitan Bank and Trust Company obtained a judgment against the petitioners. From that judgment the petitioners sought relief, and the case travelled up to the Supreme Court, which denied their petition in a Decision dated the twenty-seventh of August, 2013. Undeterred, the petitioners filed a Motion for Reconsideration of that denial. It is that motion which the Court resolved in the minute resolution now before us, and it is the last step in the case's path: from the trial court, through the Court of Appeals and the Supreme Court, and back to the Supreme Court on reconsideration.

Facts

Metropolitan Bank and Trust Company held a money judgment against the spouses Edmund Co and Lily Co and against Eduardo Rayo. To enforce that judgment, the trial court, through Judge Rita Bascos-Sarabia, issued a writ of execution, and Sheriff Adolfo Garcia, Junior proceeded to levy on and sell properties belonging to the petitioners.

Aggrieved, the petitioners went to the Supreme Court by petition, insisting that the judge and the sheriff had acted without or in excess of jurisdiction and with grave abuse of discretion in carrying out the judgment. The Court examined those arguments and, in its Decision dated the twenty-seventh of August, 2013, denied the petition.

The petitioners then filed a Motion for Reconsideration, repeating the same grounds they had raised in their petition. No new issue and no substantial matter was tendered to justify a modification, much less a reversal, of the Decision.

Issues

• Whether or not the petitioners presented new and substantial issues that would warrant a modification or reversal of the Court's Decision dated the twenty-seventh of August, 2013.
• Whether or not the Motion for Reconsideration should be granted.

Applicable Provisions

The decision does not quote or construe any statutory provision; it rests on the settled procedural rule that a motion for reconsideration must tender new and substantial matters, and on the finality of the Court's own judgments. That rule is the standard against which the motion was measured.

Ruling

On the first issue, the Court held that the petitioners failed to present new issues. Their assertions, the Court said, were a mere rehash of the arguments already stated in the petition and duly considered in the assailed ruling. A motion for reconsideration that merely repeats what has been passed upon tenders nothing substantial and cannot justify a modification, let alone a reversal.

On the second issue, the Court held that, tendering no substantial matters to justify a reconsideration or modification of its Decision, the motion must be denied for lack of merit. The Court put the point in these words:

These assertions are mere rehash of the arguments previously stated in the petition which We have duly considered in the assailed ruling.

And it concluded:

Tendering no substantial matters to justify a reconsideration or modification of Our Decision, the instant motion is hereby DENIED for lack of merit.

Doctrine

First, a motion for reconsideration must raise new and substantial matters; a mere rehash of arguments already passed upon by the Court is properly denied for lack of merit. Second, once the Supreme Court has ruled on a petition, the losing party cannot obtain a reversal by repeating the same grounds in a motion for reconsideration. Third, the denial of the petition in the Decision dated the twenty-seventh of August, 2013 stands, and the enforcement of the bank's judgment against the petitioners is left undisturbed.

Disposition

The petitioners lost; the Supreme Court denied their Motion for Reconsideration for lack of merit, and its Decision dated the twenty-seventh of August, 2013 denying their petition stands.

Remember This

The line worth memorizing is that a motion for reconsideration which is a mere rehash of arguments already considered tenders no substantial matter and must be denied for lack of merit. Examiners use this case to test the requisites of a valid motion for reconsideration and the finality of Supreme Court decisions.