Nicos Industrial Corporation v CA
GR No. 88709 February 11, 1992
Section 14. No decision shall be rendered by any court without
expressing therein clearly and distinctly the facts and the law on which it is
based.cralaw
No petition for review or motion for reconsideration of a
decision of the court shall be refused due course or denied without stating the
legal basis therefor.c
FACTS:
(1) The order is assailed by
the petitioners on the
principal ground that it violates the aforementioned constitutional requirement of Article 8 Section 14 of the
Constitution. The petitioners
claim that it
is not a
reasoned decision and
does not clearly
and distinctly explain how
it was reached
by the trial
court. Petitioners complain that
there was no analysis of their
testimonial evidence or of their 21
exhibits, the trial court merely
confining itself to the pronouncement that the sheriff's sale was valid and that it had no jurisdiction over the derivative suit.
There was therefore no adequate factual or legal basis for the decision that
could justify its review and affirmance by the Court of Appeals.
(2) January 24, 1980, NICOS Industrial Corporation obtained a loan of
P2,000,000.00 from private respondent United Coconut Planters Bank and to
secure payment thereof executed a real estate mortgage on two parcels of land
located at Marilao, Bulacan. The mortgage was foreclosed for the supposed
non-payment of the loan, and the sheriff's sale was held on July 11, 1983,
without re-publication of the required notices after the original date for the
auction was changed without the
knowledge or consent
of the mortgagor.
(3) CA decision: We hold that the order appealed from as framed by the
court a quo while leaving much to be desired, substantially complies with the
rules.
ISSUE:
Whether or not the trial court’s decision is
unconstitutional
HELD:
WHEREFORE,
the challenged decision
of the Court of
Appeals is SET
ASIDE for lack
of basis. This case is REMANDED
to the Regional Trial
Court of Bulacan, Branch 10, for
revision, within 30
days from notice,
of the Order of June 6, 1986, conformably to the requirements
of Article VIII, Section 14, of the
Constitution, subject to the appeal thereof, if desired, in accordance with
law.
RATIO:
(1) The questioned order is an
over-simplification of the
issues, and violates both
the letter and spirit of Article VIII, Section 14, of the Constitution.
(2) It is a
requirement of due
process that the
parties to a
litigation be informed
of how it
was decided, with
an explanation of the factual and legal reasons that led to the
conclusions of the court. The court cannot simply say that judgment is rendered
in favor of X and against Y and just leave it at that without any justification
whatsoever for its action. The
losing party is entitled to
know why he lost, so he may appeal
to a higher court, if permitted, should he believe that the decision should be reversed. A decision that
does not clearly and
distinctly state the facts and the law
on which it is based leaves
the parties in the dark
as to how it was reached and
is especially prejudicial to the losing party, who is
unable to pinpoint
the possible errors of the
court for review by a
higher tribunal.
(3) Brevity is doubtless an admirable trait, but it should not and
cannot be substituted for substance. As the ruling on this second ground was
unquestionably a judgment on the merits, the failure to state the factual and
legal basis thereof was fatal to the order.
(4) Kilometric decisions
without much substance must be
avoided, to be
sure, but the
other extreme, where
substance is also
lost in the
wish to be
brief, is no
less unacceptable either. The
ideal decision is
that which, with
welcome economy of
words, arrives at
the factual findings reaches the legal conclusions renders its ruling and having done so ends.
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