PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VERSUS CAMILO B. DOLAR, ACCUSED-APPELLANT.

People versus Dolar

The Case

People versus Dolar is a criminal case in which the People of the Philippines prosecuted Camilo Dolar as the accused. The accused asked the Supreme Court to reconsider a decision it had rendered against him, or in the alternative to reopen the trial so that he could present more evidence. The Court refused. The case matters to a reviewee for one narrow but durable reason: it is a clean illustration of the finality of a judgment and of the near-impossibility of reopening a decided criminal case through a motion for reconsideration. It is also a lesson in how little a reviewing court will say when it finds no cogent reason to disturb its own ruling.

Procedural History

The case travelled through the ordinary criminal hierarchy. It was tried and decided by the trial court, went up on appeal, and was resolved by the Court of Appeals. The accused then elevated the matter to the Supreme Court, which rendered a decision on the thirteenth of March 2013, adverse to him.

Acting on his own behalf, the accused filed with the Supreme Court an Omnibus Motion for Reconsideration or, in the alternative, to Reopen Trial of the Case. The People, as plaintiff-appellee, filed a Comment opposing the motion. The Supreme Court then resolved the motion in the assailed resolution now before us for study.

Facts

The decision text before us is spare. It does not narrate the crime, the evidence, or the findings of the trial court and the Court of Appeals. What it does establish is the posture of the parties at the moment of the ruling.

The accused, Camilo Dolar, stood convicted after a decision of the Supreme Court dated the thirteenth of March 2013. Seeking to overturn that result, he filed a single omnibus motion asking the Court either to reconsider its decision or, failing that, to reopen the trial of the case.

The People of the Philippines, through the Office of the Solicitor General as counsel for the plaintiff-appellee, filed a Comment resisting the motion. The Court examined both the motion and the Comment and found no cogent reason to amend, revise, or reverse its earlier decision.

Issues

• Whether or not the accused's motion for reconsideration of the Supreme Court's decision of the thirteenth of March 2013 should be granted.
• Whether or not the alternative prayer to reopen the trial of the case should be granted.

Applicable Provisions

The decision text supplied does not quote or expressly construe any statutory or constitutional provision. It rests entirely on the Court's assessment that no cogent reason exists to disturb a final judgment. No verbatim provision can therefore be reproduced without inventing text, and none is offered here.

Ruling

On the first issue, the Court denied reconsideration. Its stated reason is that, after a careful perusal of the omnibus motion and of the Comment filed by the plaintiff-appellee, it found no cogent reason to amend, revise, much less reverse its decision of the thirteenth of March 2013. The standard the Court applied is worth hearing twice: no cogent reason. A motion for reconsideration is not a second appeal; it succeeds only where the movant shows a reason weighty enough to unsettle what the Court has already adjudged.

On the second issue, the alternative prayer to reopen the trial fared no better. The Court treated the request to reopen as part of the same omnibus motion and disposed of it in the same breath, denying the motion in its entirety for lack of merit. The accused offered nothing that persuaded the Court that further proceedings were warranted.

The Court's dispositive language is itself the holding:

Wherefore, the Motion for Reconsideration is hereby denied for lack of merit.

Justices Lopez and Inting concurred.

Doctrine

A Bar candidate should retain three rules from this case.

• A motion for reconsideration requires a cogent reason. The Court will not amend, revise, or reverse its own decision absent a compelling ground; a mere re-argument of what has already been passed upon is not enough.
• A judgment, once rendered, is not lightly reopened. A prayer to reopen the trial, bundled with a motion for reconsideration, will be denied where the movant shows no merit in the motion as a whole.
• Finality serves the administration of justice. The brevity of the resolution is the doctrine: where no cogent reason appears, the Court says so and ends the matter.

Disposition

The accused lost. The Supreme Court denied his Omnibus Motion for Reconsideration or, in the alternative, to Reopen Trial of the Case for lack of merit, and its decision of the thirteenth of March 2013 stands.

Remember This

Memorize the line: no cogent reason, no reconsideration, and no reopening of the trial. Examiners use this case to test the standard for a motion for reconsideration before the Supreme Court and the finality of judgments in criminal cases.