EDUARDO J. MARIÑO, JR., MA. MELVYN P. ALAMIS AND UST FACULTY UNION, PLAINTIFFS-APPELLANTS, VS. GIL GAMILLA, JUSTINO CARDENAS AND DUPONT ASERON, DEFENDANTS-APPELLEES.

Mariño versus Gamilla

The Case

This is a labor case that reached the Supreme Court on a motion for reconsideration. Eduardo Mariño, Junior, Ma. Melvyn Alamiz, and the University of Santo Tomas Faculty Union were the plaintiffs who sued Gil Gamilla, Justino Cardenas, and Dupont Aseron. The decision before us is short and procedural: the Court refused to reconsider its earlier ruling. The case matters to a reviewee because it illustrates the finality of a Supreme Court decision and the strict standard for a motion for reconsideration — that the motion must raise a new or substantial ground, not merely reargue what was already passed upon.

Procedural History

The plaintiffs filed their action against the defendants. The case travelled through the lower courts and eventually reached the Supreme Court, which promulgated a decision on the twenty-eighth of February, 2014. The plaintiffs then filed a motion for reconsideration of that decision. The present ruling resolves that motion. The Court, through Justice Garcia-Fernandez, with Justices Tijam as Chairperson and Antonio-Valenzuela concurring, denied the motion.

Facts

The decision text before us is confined to the resolution of the motion for reconsideration. It records that the plaintiffs-appellants filed a motion for reconsideration of the decision promulgated on the twenty-eighth of February, 2014. The motion did not raise any new or substantial ground or reason. The Court found no cogent reason to warrant a reconsideration of its earlier decision.

Because the text supplied is only the resolution of the motion, the underlying facts of the labor dispute are not set out in it. What the record establishes for our purposes is simply this: a decision had already been rendered, and the losing party sought to have it reversed through a motion for reconsideration.

Issues

• Whether or not the motion for reconsideration raised a new or substantial ground or reason that would warrant reversal of the Court's decision.
• Whether or not there was cogent reason to reconsider the decision promulgated on the twenty-eighth of February, 2014.

Applicable Provisions

The decision does not quote any statutory provision. Its operative language is the Court's own formulation of the standard for reconsideration, which it applied as follows:

Acting on the motion for reconsideration filed by plaintiffs-appellants, this Court finds no cogent reason to warrant a reconsideration of the decision promulgated on February 28, 2014 since the motion has not raised any new or substantial ground or reason calling for reversal of this Court's findings.

This sentence bears on the case because it states the exact test the Court used: a motion for reconsideration must present a new or substantial ground, and absent that, reconsideration will not be granted.

Ruling

On the first issue, the Court held that the motion had not raised any new or substantial ground or reason calling for reversal of its findings. A motion for reconsideration, in the Court's view, is not a vehicle for rearguing matters already resolved; it must point to something new or substantial.

On the second issue, the Court found no cogent reason to warrant a reconsideration of its decision of the twenty-eighth of February, 2014. Having found neither a new nor a substantial ground, it denied the motion. The Court's reasoning rests on its own stated standard, quoted above, and it applied that standard strictly to the motion before it.

Doctrine

A motion for reconsideration must raise a new or substantial ground or reason calling for reversal of the Court's findings. Absent such a ground, and absent cogent reason, the motion will be denied. A motion that merely repeats arguments already passed upon does not meet the standard. The decision of the Supreme Court, once promulgated, is not lightly disturbed; reconsideration is the exception, not the rule.

Disposition

The motion for reconsideration was denied, and the decision of the twenty-eighth of February, 2014 stands.

Remember This

Memorize the line: no cogent reason and no new or substantial ground means no reconsideration. Examiners use this case to test the standard for a motion for reconsideration and the finality of Supreme Court decisions.