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[G.R. No. 159357. April 28, 20A4.1

Brother MARIANO rrMIKErr z. YELARDE, petitioner, vs. socIAL

JUSTICE SOCIETY, tespondent
i

DECISION
PANGANIBAI..I,

J:

A decision that does not conform to the form and

substance requfued by the Constitution and the

law is void and deemed legally inexistent. To be valid, decisioas should
with the form, rhe
"omply
procedure and the substantive tequirements laid out in the Constitution,
thi Rules of Court and
relevant circulars/orders of the Supreme Court. For the guidance of the bench and the bar, the
Court hereby discusses these forms, procedures and reqrrirements.

The Case
Before us is a Petition for Review under Rule 45 of the Rules of Court, assailng tle
Decision and July 29 , 2003 Otder of the Regional Trial Cour (RTC) of Manila

Jrn. 12,2003

1B-ran.h +O),

Aleging that the questioned Decision did not contain a statelnent of facts and a dispositive portion,
hetein petitioner filed a Clarificatory Motiou and Motion for Reconsidetation before the trial court.
Sodano, his co-tespondeng similarly filed a separate Motion for Reconsideration. In response, the

ttirl court

issued the assailed Order, which held as ft"rllows:

". . . [Ilhit Cout canflot reconsider, because what it was asked to do, was
only to clarjrty a Constitutional provision and to declare whether acts are

violative theteof. The f)ecision did not make a dispositive portion bec.ause a
dispositive portion is tequired only in coetciye reliefs, where a redress from
wtong suffeted and the benefit that the ptevailing party wrooged should get.
The step that these movants have to take, is direci appeal orl", Rule 45 of
the Rules of Court, fot a conclusive interpretation
tfr. Constitutional
"f
provision to the Supreme Court.,,

The Issues

1'

Did the RTC Decision confotm to the form and substance required by the Constitution, the
law
and the Rules of Court?xxx
The Court,s Ruling

Fitst Substantive Issue:n Fundaniental Requirements! of a Decision

Parts of a Decision

In general, the essentia|-Punt of a good decision consist of the following: (1)lstatemenr of the case;
(2) statement of facts; (3) issues or assignment of errom; (4) court fug, * which
ir.... i.,-ur l
"".t may
rule, separately considered and resolved; and, finally, (5; dispositive poltion. The ponenre
also

opt to include an inttoducdon or a prologue

as weJi as an epilogue, especially

in

cases

in which

conftovetsial or novel issues are involved

An inUoduction may consist of a concise but comprehensive statement of the principal factual or
patticulatly those concetaing public interest; or involving
legal issue/s of the case, In some cases
a longer
complicated commetcial, scientific, technical or otherwise rare subiect matters
introduction or prologue may serve to acquaint teaders with the specific nature of the contlovemy
and the issues involved. An epilogue may be a summafion of the important pfnciples applied to the
tesolution of the issues of paramount public intetest or signifi.cance. It may also iay down an
enduting philosophy of law or guiding principle.

Let us now, again for the guidance of the trench and the bat, discuss the essential parts of a good
decision.

l.Statement of the Case

The Statement of the Case consists of a legal definition of the nature of the action. At the fust
instance, this part states whether the acdon is a civil case for collection, ejectment, quieting of title,
foreclosure of mortgage, and so or5 or, if it is a criminal case, this patt describes the specific charge
and the plea of the accused.
quoted usually ftom the accusatory pottion of &e information
-Also mentioned Lete are whether the case is being decided on appeal- or on a petition for certiorari,
the court of origin, the case numbet in the tdal coutt, and the dispositive potion of the assailed
decision.
case, the verbatim reptoduction of the criminal infotmation serves as a guide in
determining the nature and the gravity of the offense fot which the accused may be found culpable.
As a rule, the accused cannot be convicted of a crime different ftom ot graver than that charged.

In a criminal

Also, quoting verbatim the text of the information is especially important when thete is a question
on the sufficiency of the charge, or on whether quali$ring and modifying circumstances have been
adequately alleged thetein.

To ensure that due process is accorded, it is important to give a short description of the proceed.ings
tegarding the plea of the accused. Absence of an artaignment, ot a serious irregularity therein, may
render the judgment void, and further consideration by the appellate court would be futile. In some
instances, especially in appealed cases, it would also be useful to mention the fact of the appellants'
whether or not they have abandoned their
detention, irordet to diipose of the preliminary que*y

Mentioning the court of otigin and the case number originally assigned helps in facilitating the
consolidation of the records of the case in both &e trial and the appellate courts, after entty of final

iudgment.

Finally, the reproduction of the decretal portion of the assailed decision infcjrms the reader of how
the appealed case was decided by the coutt a quo.
2.Statemeot of Facts

There are different ways of reiating the facts of the case. First, undet the objective or reportorial
the testimony of each witness and the
method, the judge summarizes * without comment

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cofltents of each exhibit' second, under the synthesis method' the factual theoq' of the plaintiff or
prosecution and then that of &e defendant or defense is summatbed zccording to the iudge's best
iight Third, in the subiective method, the version of the facts acceptSd by the judge is simply
narrated without explaining what the parties' vetsions are. Finally, thtough a combination of
objective and subiective means, the testimony of each witness is repotted and the iudge then
formulates his or het own vetsion of the facts.

In cdminal cases, it is better to pfesent both the version of the ptosecution a'nd that of the defense,
in the interest of fairness and due process. A detailed evaluation of the coritentions of the parties
must follow. The resolution of most criminal cases, unlike civil and other cases, depends to a large
extent on the factual issues and the appreciation of the evidence. The plausibiJity or the
rmplausibility of each vetsion can somedmes be initially drawn from a reading of the facts.
Thlreafter, the bases of the court in arriving at its findings and conclusions should be explained.

On appeal, the fact that the assailed decision of the lower court fully, rntelligently and correctly
tesolrcd all factual and legal issues involved may patly explain why the teviewing couft finds no
reasoo to reverse the findings and conclusions of the former. Conversely, the lowet court's Patent
-or
misapplication of the,law would aid in a better undetstanding of why
misappreciation of the facts
its ruling is teversed or

modified

In. appealed civil cases, the opposing sets of facts no longer need to be presented' Issues for
tesolution usually involve questions of law, gtave attuse of discretion, ot waflt of judsdiction; hence,
the facts of the case are often undisputed by the parties. With few exceptions, factual issues ate not
entetained in non-criminal cases. Consequently, th" aaration of facts by the lower court, if
exhaustive and clear, may be reproduced; otherwise, the matedal factual antecedents should be
testated in the words of the reviewing magistrate.

In addition, the reasoning of the low-er court ot body whose decision is under rer,'iew should be laid
out, in order ffrat the parties may cleatly understand why the lower court ruled in a certain way, and
why &e tevierving court either finds no reason to reverse it or conciudes otherwise,
3.Issues or Assignment of Ertots

Both factual and legal issues should be stated. On appeal the assigrrment of erots, as mentioned in
the appellant's btief, may be reproduced in toto and tackled seriatim, so as to avoid motions for
reconsideration of the final decision on the gtound that the court failed to consider all assigned
errors that could affect the outcome of the case. But when the appellant presents repetitive issues or
when &e assigned errors do not strike at the main issue, these may be restated in clearer and mote
coherent teffns.

Though not specifically questioned by the patties, additional issues may also be included, if deemed
important for substantial justice to be tendered. Note that appealed criminal cases are given de novo
review, in cofltrast to noncrimjnal cases in which the revierving court is generally limited to issues
specif,cally raised in the appeal. The few exceptions are errors of jurisdiction; questions not taised
but necessary in arriving at a just decision on the case; or unassigned errors that are.closely related to
those proper$ assigoed, or upon which depends the determinauon of the question,froperlv raised.
4.The Court's Ruling

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This part contains a full discussion of the specific errof,s or issues raised in the complaint, petition ot
appeal, as the case may be; as well as of other issues the court deems essential to a just disposition of
tlle case, Whete there are several issues, each one of them should be separatqly addressed, as much
as practicable. The tespective contentions of the paries should also be mentioned here. When
procedural questions are raised in addition to substantive oiles, it is better to resolve the former
pteliminadly.
5.The Disposition or Dispositive Portion

In a criminal

case, the disposition should include a findrng

of innocence or guilt, the specific crime

committed, the penalty imposed, the particrpation of the accused, the modi$ring circumstances if
any, aod the civil liability and costs. In case an acquittal is decteed, the court must otder the
immediate release of the accused, if detained, (unless they are being held for another cause) and
ordet the dfueitot of the Buteau of Cotections (or wherever the accused is detained) to report,
within a maximum of ten (10) days from notice, t}e exact date when the accused were ser free.i

In a civil case as well as in a special civil action, the disposition should state whether the complaint
ot petition is granted or denied, the specific relief gmnted, and the costs. The following test of
completeness may be applied. Fitst, the parties should knorv their rights and obligations. Second,
they should know how to execute the decision under altemative condngencies. Third, there should
be no need for further ptoceedings to dispose of the issues. Fourth, the case should be terminated
by according the proper telief. The "proper relief' usually depends upon what the parties seek in

their pleadings.

It

may declare their rights and duties, command the performance of positive

prestations, or order them to abstain from specific acts. The disposition must also adiudicate costs.

The fotegoing parts need not always be discussed in sequence. But they should all be present and
plainly identifiable in the decision. Depending on the writ-er's character, genre and style, the language
should be ftesh and free-flowing, flot necessarily stereotyped or in a {ixed form; muctr tot
highfalutin, hackneyed and pretentious. At all times, however, the decision must be clear, concise,
complete and

correct.

IflHEREFORE, the Petition fot Review of Brother Mike Velarde is GRANTED. The assailedJune
72,2003 Decision and July 29,2003 Order of the Regional Trial Court of Manila (Branch 49) are
helebY DECLARED NULL AND VOID and thus SET ASIDE. The SJS Petition for Declatatory
Relief is DISMISSED for failue to state a cause of acrion.
Let a copy of this Decision be fumished the Office of the Court Administtator to evaluate and
tecommend whethet the trial judge may, after obserrring due process, be held administratively liable
for rendering a decision violative of the Constitution, th.e Rules of Court and relevant circulats of
this Court. No costs.
SO ORDERED.