Case No.

881
ART. VIII. SEC. 14. LEGAL BASIS MUST BE STATED IF A PETITION FOR REVIEW OF MOTION
FOR RECONSIDERATION IS REFUSED OR DENIED
Protacio v. Laya | 582 SCRA 417

FACTS: Protacio filed a petition for review on the CA’s resolution denying his motion for
reconsideration which reduced the monetary award granted by the NLRC.

ISSUE: Whether the constitutional requirement applies to resolutions.

RULING: NO. The assailed resolution is not a "decision" within the meaning of the Constitutional
requirement. This mandate is applicable only in cases submitted for decision, that is given due
course and after filing of briefs or memoranda and/or other pleadings, as the case may be. The
requirement is not applicable to a resolution denying a motion for reconsideration of the
decision. What is applicable is the 2 nd paragraph of Sec. 14, Art. VIII referring to "motion for
reconsideration of a decision of the court." In this case, the assailed resolution complied with the
requirement therein that a resolution denying a motion for reconsideration should state the legal
basis of the denial. It sufficiently explained that after reading the pleadings filed by the parties, the
appellate court did not find any cogent reason to reverse itself.

Case No. 882

ART. VIII. SEC. 14. LEGAL BASIS MUST BE STATED IF A PETITION FOR REVIEW OF MOTION
FOR RECONSIDERATION IS REFUSED OR DENIED
Nationwide Security and Allied Services, Inc. v. Ronald P. Valderama | G.R. No. 186614

FACTS: Ronald, a security guard, was constructively dismissed as ruled by the Labor Arbiter.
Petitioner field a petition for review before the CA, but the CA sustained the Labor Arbiter’s
decision.

ISSUE: Whether the CA stated a legal basis in denying the petition for review.

RULING: YES. This case reiterated Philippine Health Care Providers, Inc. v. CIR, the constitutional
requirement under the 1st paragraph of Sec. 14, Article VIII of the Constitution that the facts
and the law on which the judgment is based must be expressed clearly and distinctly applies
only to decisions, not to minute resolutions. A minute resolution is signed only by the clerk of
court by authority of the justices, unlike a decision. It does not require the certification of the Chief
Justice. Moreover, unlike decisions, minute resolutions are not published in the Philippine Reports.
Finally, the proviso of Section 4(3) of Article VIII speaks of a decision. Indeed, as a rule, this Court
lays down doctrines or principles of law which constitute binding precedent in a decision duly
signed by the members of the Court and certified by the Chief Justice. In this case, the CA adopted
the findings of the LA.
 CASE NO. 883
Art. VIII, Sec. 14: Legal basis must be stated
Re: Verified Complaint of Engr. Oscar L. Ongjoco,
A.M. OCA IPI No. 11-184-CAJ, 31 January 2012

FACTS: Engr. Oscar L. Ongjoco, claiming himself to be the CEO of the FH-GYMN Transport Service
Cooperative, filed an administrative complaint against respondent Justices of the Court of Appeals.
In the complaint, Ongjoco maintained that respondent members of the CA’s Sixth Division violated
Section 14, Article VIII of the 1987 Constitution by not specifically setting forth the basis for
denying the five issues FH-GYMN’s petition for review raised.

ISSUE: WON there is a violation of Sec. 14, Art. VIII of the Consti.

RULING: NO. The essential purpose of the Sec. 14, Art. VIII of the Constitution is to require
that a judicial decision be clear on why a party has prevailed under the law as applied to the
facts as proved; the provision nowhere demands that a point-by-point consideration and
resolution of the issues raised by the parties are necessary. This constitutional provision deals
with the disposition of petitions for review and of motions for reconsideration.

In appellate courts, the rule does not require any comprehensive statement of facts or mention of
the applicable law, but merely a statement of the "legal basis" for denying due course.

Indeed, the definitive pronouncement of the CA’s Sixth Division that "the Deputy Ombudsman
found no substantial evidence to prove that there was interference in the internal affairs of FH-
GYMN nor was there a violation of the law by the respondents" met the constitutional demand for a
clear and distinct statement of the facts and the law on which the decision was based. The CA’s
Sixth Division did not have to point out and discuss the flaws of FH-GYMN’s petition considering
that the decision of the Deputy Ombudsman sufficiently detailed the factual and legal bases for the
denial of the petition.

CASE NO. 884

Art. VIII, Sec. 14: Legal basis must be stated
Agoy v. Araneta Center, GR 196358, 21 March 2012

FACTS: The Court issued a minute resolution denying the petition for review on certiorari filed by
petitioner for failure to show that the CA committed reversible error when it affirmed the dismissal
of petitioner. However, petitioner doubted its authenticity since he filed a motion to rescind the
same and to have his case resolved on its merits via a regular resolution or decision signed by the
Justices who took part in the deliberation. Later, the Court denied petitioner’s motion to rescind
which was treated as a motion for reconsideration and denied with finality.

ISSUE: WON it was proper for the Court to deny his petition through a minute resolution.
RULING: YES. The adjudication of a case by minute resolution is an exercise of judicial discretion
and constitutes sound and valid judicial practice. While the Constitution requires every court to
state in its decision clearly and distinctly the fact and the law on which it is based, the
Constitution requires the court, in denying due course to a petition for review, merely to
state the legal basis for such denial as provided under Sec. 14, Art. VIII of the Constitution.

With the promulgation of its Internal Rules, the Court itself has defined the instances when cases
are to be adjudicated by decision, signed resolution, unsigned resolution or minute resolution.

Among those instances when a minute resolution shall issue is when the Court "denies a petition
filed under Rule 45 of the [Rules of Court], citing as legal basis the absence of reversible error
committed in the challenged decision, resolution, or order of the court below." The minute
resolutions in this case complied with this requirement.

Case 885
Art. VIII, Sec. 15 Period for making decisions
Dizon v. Judge Lopez- 278 SCRA 483 [1997]

FACTS: This is a complaint charging Judge Lilia C. Lopez of the Regional Trial Court, Branch 109,
Pasay City, with violation of the Constitution, serious misconduct, inefficiency, and falsification in
connection with her decision in Criminal Case entitled "Pp v. Engineer Fernando S. Dizon."

Complainant alleges that the failure of respondent judge to furnish him a copy of the decision until
almost 1 year and 8 months after the promulgation of its dispositive portion on April 22, 1993
constitutes a violation of Sec. 15 of the same Art. VIII.

ISSUE: WON respondent Judge violated Sec. 15, Art. VIII of the Constitution.

RULING: YES. Although respondent judge promulgated her decision within three months of the
submission of the case for decision, the fact is that only the dispositive portion was read at such
promulgation.

It is clear that merely reading the dispositive portion of the decision to the accused is not sufficient.
It is the judgment that must be read to him, stating the facts and the law on which such judgment is
based. Since this was done only on December 16, 1994 when a copy of the complete decision was
served on complainant, it is obvious that the respondent failed to render her decision within three
months as required by Art. VIII, Sec. 15 of the Constitution.

The Constitutional requirement under Section 15, Article VIII must be strictly complied with,
and if external factors, or factors not within control of the judge should arise, the Judge can
apply for extension of time to decide the case and put off the promulgation of judgment until
finished.