PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. NARCISO ENANO Y ARCA, ACCUSED-APPELLANT.

People versus Enano

The Case

This is a criminal case in which the People of the Philippines prosecuted Narciso Enano y Arca as the accused, and Enano comes before the Supreme Court as the accused-appellant. The matter reached the Court through a motion for reconsideration of the Court's own decision of June 19, 2014, to which the appellee, the People, filed a comment. The case matters to a reviewee not for any new doctrinal pronouncement, but as a study in the finality of judgment: it shows how the Supreme Court treats a motion for reconsideration that merely recycles arguments already weighed and rejected, and it reminds us that a judgment, once rendered, is not reopened for reasons that are not valid, cogent, and justifiable.

Procedural History

The decision text before us is the Court's resolution on the accused-appellant's motion for reconsideration. The record begins with the Supreme Court's decision dated June 19, 2014, which resolved the appeal of the accused-appellant. From that decision, the accused-appellant filed a motion for reconsideration, and the appellee, the People of the Philippines, filed a comment on that motion. The Court then evaluated the motion and its comment and issued the present resolution denying the motion. The text does not set out the rulings of the trial court or of the Court of Appeals, and it does not describe the intermediate steps by which the case first reached the Supreme Court; it speaks only of the decision of June 19, 2014 and of the motion for reconsideration filed against it.

Facts

The material facts, as they appear in the text, are procedural rather than factual. The Supreme Court rendered a decision on June 19, 2014 in the case against Narciso Enano y Arca. The accused-appellant then filed a motion for reconsideration of that decision, seeking a modification, or in the alternative a reversal, of the judgment.

The People of the Philippines, as appellee, filed a comment on the motion. The Court examined the motion and the comment and found that the movant had presented no valid, cogent, and justifiable reason that would convince the Court to modify or reverse its judgment.

The Court further observed that the arguments raised in the motion had already been considered and weighed when the Court rendered the decision under attack. On that basis, the Court concluded that there was no need to belabor the issues one more time, and it denied the motion.

Issues

• Whether or not the accused-appellant's motion for reconsideration presents a valid, cogent, and justifiable reason to modify or reverse the Court's decision of June 19, 2014.
• Whether or not the arguments raised in the motion for reconsideration were already considered and weighed in the decision sought to be reconsidered, such that there is no need to belabor the issues again.

Applicable Provisions

The decision text before us does not quote or construe any statutory or constitutional provision; it rests on the settled rule against re-litigating matters already passed upon. The only dispositive language in the text is the Court's own concluding formula, which it uses to deny the motion:

WHEREFORE, the foregoing considered, WE DENY the said Motion for Reconsideration.

This is the operative ruling of the resolution, and it bears on the case by showing that the denial rests on the absence of any valid, cogent, and justifiable reason rather than on any new statutory ground.

Ruling

On the first issue, the Court held that the motion for reconsideration was wanting in merit. It found that no valid, cogent, and justifiable reason was presented by the movant that would convince the Court to come up with a modification, much less a reversal, of the judgment. The Court stated the standard plainly:

No valid, cogent, and justifiable reason was presented by the movant that would convince this Court to come-up with a modification, much less, a reversal of the said judgment.

On the second issue, the Court held that the arguments raised in the motion had already been considered and weighed when it rendered the assailed decision. Because those arguments had already been passed upon, the Court saw no need to belabor the issues one more time. The Court thus declined to reopen what it had already decided and denied the motion.

Doctrine

A motion for reconsideration must rest on a valid, cogent, and justifiable reason that would move the Court to modify or reverse its judgment; a motion that offers none is denied. Arguments that were already considered and weighed in the decision sought to be reconsidered cannot be raised again to reopen the case, for there is no need to belabor issues already passed upon. Stated as a rule for the Bar answer: the Supreme Court will not modify, much less reverse, its own judgment on the strength of reasons that are not valid, cogent, and justifiable, and it will not re-examine arguments it has already resolved.

Disposition

The Court denied the accused-appellant's motion for reconsideration, leaving the decision of June 19, 2014 undisturbed.

Remember This

The line worth memorizing is that a motion for reconsideration stands or falls on a valid, cogent, and justifiable reason, and arguments already weighed in the decision cannot be belabored again. Examiners use this case in remedial law and criminal procedure to test the requisites of a motion for reconsideration and the finality of judgments.