RODEL ARCA, PETITIONER, VS. JOAQUIN MENDOZA & ESTELA BERNARDO AND HON. DENNIS PATRICK Z. PEREZ, PRESIDING JUDGE OF RTC BR. 67 BINANGONAN, RIZAL, RESPONDENTS.

Rodel Arca versus Joaquin Mendoza and Estela Bernardo

The Case

This is Rodel Arca versus Joaquin Mendoza and Estela Bernardo, together with the presiding judge of a regional trial court in Binangonan, Rizal. Arca is the petitioner; Mendoza and Bernardo are the private respondents, and the judge is impleaded in his official capacity. The matter before the Supreme Court is a motion for reconsideration filed by the petitioner, asking the Court to set aside its earlier resolution. The case matters to a reviewee for a narrow but practical reason: it shows the Supreme Court applying the settled rule that a motion for reconsideration must raise a new or substantial ground, and that a bare reargument will not disturb a final resolution.

Procedural History

The decision text before us is itself the Supreme Court's resolution on the motion for reconsideration. It recites that the Court had earlier issued a resolution promulgated on February 24, 2014, and that the petitioner then filed a motion for reconsideration of that resolution. Acting on that motion, the Court found no cogent reason to reconsider. The resolution on the motion was penned by Justice Garcia-Fernandez, with Justice Lampas Peralta as Chairperson and Justice Antonio-Valenzuela concurring. The text does not set out the rulings of the trial court or of the Court of Appeals, and we do not supply them here.

Facts

The material facts, as the decision text discloses them, are procedural. The Supreme Court issued a resolution on February 24, 2014. The petitioner, Rodel Arca, responded by filing a motion for reconsideration of that resolution.

The motion did not present any new or substantial ground or reason. It sought a reversal of the Court's findings on the strength of the arguments already made.

The Court examined the motion and found no cogent reason to warrant reconsideration. It accordingly resolved the motion in the manner set out in the disposition.

Issues

• Whether or not the motion for reconsideration filed by the petitioner raised a new or substantial ground or reason that would justify reversing the Court's resolution of February 24, 2014.
• Whether or not the motion for reconsideration should be granted.

Applicable Provisions

The decision text does not quote or construe any statutory or constitutional provision. It rests on the Court's own prior resolution and on the settled standard for reconsideration, which the Court states in its own words:

Acting on the motion for reconsideration filed by petitioner, this Court finds no cogent reason to warrant a reconsideration of the resolution promulgated on February 24, 2014 since the motion has not raised any new or substantial ground or reason calling for reversal of this Court's findings.

This sentence is the operative standard in the case: reconsideration lies only where the motion raises a new or substantial ground or reason.

Ruling

On the first issue, the Court held that the motion raised no new or substantial ground or reason calling for reversal of its findings. It found no cogent reason to reconsider the resolution of February 24, 2014. The Court's reasoning is captured in its own formulation:

the motion has not raised any new or substantial ground or reason calling for reversal of this Court's findings.

On the second issue, because the threshold requirement was not met, the Court denied the motion for reconsideration. The denial follows directly from the absence of any new or substantial ground; the Court did not reopen the merits of its earlier resolution.

Doctrine

A motion for reconsideration must raise a new or substantial ground or reason. Where it does not, and merely repeats what has already been passed upon, the Court will find no cogent reason to reconsider its resolution, and the motion will be denied. The rule is stated in the decision itself: reconsideration is warranted only where the motion raises a new or substantial ground or reason calling for reversal of the Court's findings. A bar answer should frame this as a procedural rule of finality: the resolution stands unless the movant shows a new or substantial ground, and the burden is on the movant.

Disposition

The motion for reconsideration was denied, and the resolution of February 24, 2014 stands.

Remember This

Memorize the line: no new or substantial ground or reason means no cogent reason to reconsider. Examiners use this case for the procedural rule on motions for reconsideration and for the finality of a resolution that a bare reargument cannot disturb.