PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ANTONIO CABADOR, ET AL., ACCUSED-APPELLANT.

People versus Cabador

The Case

This is a criminal case in which the People of the Philippines prosecuted Antonio Cabador and his co-accused, with Martin Jimenez appearing before the Supreme Court as the accused-appellant. The action began as a criminal prosecution in the Regional Trial Court of Quezon City and rose to the Supreme Court on appeal, where the Court affirmed the conviction and the award of damages, and later denied the accused-appellant's motion for reconsideration. The case matters to a reviewee because it illustrates the finality of the Court's findings of fact on appeal, the narrow grounds on which a motion for reconsideration may succeed, and the propriety of an award of exemplary damages in a criminal judgment.

Procedural History

The case was tried by the Regional Trial Court, Branch 81, Quezon City, which rendered a Joint Decision dated February 3, 2009 in two criminal cases. The accused appealed to the Supreme Court. On October 8, 2014, the Supreme Court promulgated its Decision affirming the Joint Decision of the trial court, with the modification that exemplary damages in the amount of 30,000 pesos were also awarded. The accused-appellant Martin Jimenez then filed a Motion for Reconsideration of that Decision. The Office of the Solicitor General filed its Comment, opposing the motion and traversing the arguments of the accused-appellant. The Supreme Court resolved the motion in the decision now before us.

Facts

The material facts are procedural rather than narrative. The Regional Trial Court of Quezon City, Branch 81, tried two criminal cases against Antonio Cabador and others and, on February 3, 2009, issued a Joint Decision in both cases. The accused appealed, and the appeal reached the Supreme Court.

On October 8, 2014, the Supreme Court rendered its Decision affirming the Joint Decision of the trial court, but modifying it by adding an award of exemplary damages in the amount of 30,000 pesos. The dispositive portion of that Decision ordered accordingly.

Aggrieved, the accused-appellant Martin Jimenez filed a Motion for Reconsideration of the October 8, 2014 Decision. The Office of the Solicitor General filed its Comment traversing his arguments. Upon consideration, the Court found that the arguments raised were mere reiterations of arguments previously raised and already considered and extensively discussed in its earlier Decision.

Issues

• Whether or not the Motion for Reconsideration filed by accused-appellant Martin Jimenez raises substantive or compelling reasons to reconsider or reverse the findings of the Court.
• Whether or not the arguments in the motion are mere reiterations of arguments already raised and passed upon in the Court's earlier Decision.

Applicable Provisions

No statutory provision is quoted or construed in the decision text. The Court's ruling rests on the procedural principle that a motion for reconsideration must present substantive or compelling reasons, and on the settled rule that arguments already considered and extensively discussed in the assailed Decision do not warrant reconsideration. The dispositive portion of the earlier Decision, which the Court quotes, provides:

WHEREFORE, the Joint Decision dated February 3, 2009 of the Regional Trial Court, Branch 81, Quezon City, in Criminal Case Nos. Q-00-93291 and Q-00-93292 is AFFIRMED with MODIFICATION in that exemplary damages in the amount of P30,000.00 is also awarded.

This quoted disposition fixes the judgment that the motion for reconsideration sought to overturn, and it is the judgment the Court declined to disturb.

Ruling

On the first issue, the Court held that there were no substantive or compelling reasons to reconsider or reverse its findings. It carefully considered and evaluated the arguments raised in the motion and found none sufficient to justify a reversal.

On the second issue, the Court held that the arguments raised by the accused-appellant were mere reiterations of arguments previously raised, which the Court had already considered and extensively discussed in its Decision of October 8, 2014. Having found no substantive or compelling reasons, the Court denied the motion for lack of merit. The Court's disposition states:

WHEREFORE, the Motion for Reconsideration is DENIED for lack of merit.

The Court thus left intact its earlier judgment affirming the Joint Decision of the trial court, as modified by the award of exemplary damages in the amount of 30,000 pesos.

Doctrine

A motion for reconsideration must be grounded on substantive or compelling reasons; arguments that merely repeat matters already raised, considered, and extensively discussed in the assailed Decision do not warrant reconsideration or reversal. Where the Court finds only such reiterations, it will deny the motion for lack of merit and leave its judgment undisturbed. The doctrine reinforces the stability of the Court's findings and the finality of its dispositions, including the award of exemplary damages in the criminal judgment affirmed in this case.

Disposition

The Supreme Court denied the Motion for Reconsideration for lack of merit, leaving standing its earlier Decision affirming the Joint Decision of the trial court with the modification awarding exemplary damages in the amount of 30,000 pesos.

Remember This

The single line worth memorizing is that a motion for reconsideration founded on mere reiterations of arguments already considered and extensively discussed presents no substantive or compelling reason and must be denied for lack of merit. Examiners like to use this case to test the requisites of a valid motion for reconsideration and the rule that appellate findings of fact, once settled, are not reopened by repetition.