SONNY BATUYONG, ET AL., PETITIONERS, VS. THE NATIONAL LABOR RELATIONS COMMISSION, WILLY SIA AND MYRNA GARCIA SIA, RESPONDENTS.

Batuyong versus National Labor Relations Commission

The Case

This is a labor case that reached the Supreme Court on a motion for reconsideration. The petitioners, Sonny Batuyong and others, sought relief against the National Labor Relations Commission and against Willy Sia and Myrna Garcia Sia. The decision before us is the Court's resolution of the petitioners' motion for reconsideration of the Court's earlier Decision dated September 18, 2013. The case matters to a reviewee for a narrow but practical reason: it illustrates how the Supreme Court treats a motion for reconsideration that raises no new matters of substance, and it reminds us that a motion for reconsideration is not a second appeal.

Procedural History

The petitioners filed a Motion for Reconsideration of the Supreme Court's Decision dated September 18, 2013. The motion was directed to the Court itself, asking it to reconsider its earlier ruling. The Court, through the Division, resolved to deny the motion. The resolution records that Justices Lopez and Inting concurred.

Facts

The decision text before us is spare. It tells us that the petitioners are Sonny Batuyong and others, and that the respondents are the National Labor Relations Commission, Willy Sia, and Myrna Garcia Sia. It tells us that the Court had already issued a Decision on September 18, 2013.

After that Decision, the petitioners filed a Motion for Reconsideration. The motion is the only matter placed before the Court in this resolution.

The Court examined the motion and found that it raised no new matters of substance. On that ground, the Court resolved to deny it.

Issues

• Whether or not the petitioners' Motion for Reconsideration of the Decision dated September 18, 2013 raised new matters of substance that would warrant reconsideration of the Decision.
• Whether or not the Motion for Reconsideration should be granted.

Applicable Provisions

The decision text supplied does not quote or construe any statutory or constitutional provision. It applies only the settled rule on motions for reconsideration, which the Court states in its own words:

We resolve to DENY the same as the motion raised no new matters of substance which would warrant reconsideration of our Decision.

This formulation bears on the case because it supplies the standard the Court used: a motion for reconsideration must raise new matters of substance to succeed.

Ruling

On the first issue, the Court held that the motion raised no new matters of substance. That finding is the heart of the resolution. The Court did not re-examine the merits of the September 18, 2013 Decision; it examined only whether the motion presented anything new that would justify reconsideration. Finding none, it denied the motion.

On the second issue, the Court denied the Motion for Reconsideration for lack of merit. The dispositive portion states:

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

The reasoning is therefore simple and procedural: a motion for reconsideration that merely repeats or reargues what has already been passed upon, without raising new matters of substance, must fail.

Doctrine

A motion for reconsideration must raise new matters of substance to warrant reconsideration of a decision. A motion that raises no new matters of substance is denied for lack of merit. The standard is not whether the movant disagrees with the ruling, but whether the movant presents something new and substantial that the Court has not yet considered.

For the Bar candidate, the rule may be stated in an answer thus: a motion for reconsideration is not a vehicle for rearguing the same points; it must present new matters of substance, and absent that, the Court will deny it for lack of merit.

Disposition

The Motion for Reconsideration was denied for lack of merit, so the petitioners did not obtain the relief they sought and the respondents prevailed on the motion.

Remember This

Memorize the line: a motion for reconsideration that raises no new matters of substance is denied for lack of merit. Examiners use this case in remedial law and labor procedure to test whether a candidate knows the function and limits of a motion for reconsideration.