CELDRED P. RIVERA, AVELINO DERAIN, JR., ARNEL E. ROSALES, WILLEX T. BOMBEO, ALEXANDER CORPUS AND MARCELINO EBARDO, PETITIONERS, VS. NATIONAL LABOR RELATIONS COMMISSION, BEST ENG…

Rivera versus National Labor Relations Commission

The Case

This is a labor case that reached the Supreme Court as a motion for reconsideration. The petitioners, led by Celdred Rivera, sought to overturn a decision the Court had already rendered against them. The case matters to a Bar candidate not for its labor doctrine but for a procedural lesson: a motion for reconsideration that merely repeats arguments already raised and resolved will be denied. The Court's ruling is a short, sharp statement of that rule.

Procedural History

The Court had earlier issued a decision on June 3, 2014, which was adverse to the petitioners. Dissatisfied with that decision, the petitioners filed a motion for reconsideration. Upon perusal of the motion, the Court found that it merely reiterated the arguments earlier raised, all of which had already been squarely addressed and resolved. The Court then issued the present resolution denying the motion.

Facts

The petitioners, Celdred Rivera and several others, were parties in a labor dispute against the National Labor Relations Commission and Best Eng. The Court rendered a decision on June 3, 2014, resolving the case against the petitioners.

Seeking to reverse that outcome, the petitioners filed a motion for reconsideration. The motion, however, did not present new matter. Instead, it repeated the same arguments that the Court had already considered and resolved in its earlier decision.

The Court examined the motion and found it glaringly wanting in new matter sufficiently persuasive to warrant modification of the judgment. The motion was therefore denied.

Issues

• Whether or not a motion for reconsideration that merely reiterates arguments already raised and resolved by the Court should be denied.
• Whether or not the petitioners' motion for reconsideration presented new matter sufficiently persuasive to induce modification of the judgment.

Applicable Provisions

The Court applied the settled rule on motions for reconsideration, stating:

A motion for reconsideration which does not make out new matter sufficiently persuasive to induce modification of judgment will be denied.

This rule governs whether a motion for reconsideration can succeed: it must raise new matter, not repeat what was already resolved.

The Court also stated the requirement for a party seeking reconsideration:

A party desiring to have a resolution reconsidered should point out facts or points which were not considered in the resolution.

This clarifies the burden on the movant: to identify facts or points overlooked by the Court, not to re-litigate settled arguments.

Ruling

On the first issue, the Court held that the motion for reconsideration must be denied. A perusal of the motion glaringly revealed that it merely reiterated the arguments earlier raised, which had all been squarely addressed and resolved by the Court. The Court applied the rule that a motion for reconsideration which does not make out new matter sufficiently persuasive to induce modification of judgment will be denied.

On the second issue, the Court found that the petitioners failed to comply with the requirement that a party desiring reconsideration should point out facts or points which were not considered in the resolution. Since the motion presented no new matter, it was denied.

Doctrine

A motion for reconsideration that merely reiterates arguments already raised and resolved by the Court is procedurally infirm and will be denied. The movant bears the burden of pointing out facts or points not considered in the resolution; failure to do so warrants denial. This rule is tied to the Court's statement that a motion for reconsideration which does not make out new matter sufficiently persuasive to induce modification of judgment will be denied.

Disposition

The motion for reconsideration was denied. The Court's decision of June 3, 2014 stands.

Remember This

A motion for reconsideration that merely repeats old arguments is denied; it must present new matter sufficiently persuasive to change the judgment. Examiners use this case to test the procedural requirements for a motion for reconsideration.