CA to trial court judges: cite legal basis in decisions

The Court of Appeals (CA) has reminded trial courts judges of the Supreme Court’s (SC) admonition against the issuance of decisions which have no reference to any legal basis or legal authority to support their conclusions, and with no summation of facts.

In a decision written by Associate Justice Ruben Reynaldo G. Roxas, the CA cited a 2000 SC decision which states:

“The RTC (regional trial court) decision is brief indeed, but it is starkly hallow, otiosely written, vacuous in its content and trite in its form. It achieved nothing and attempted at nothing, not even at a simple summation of facts which could easily be done. Its inadequacy speaks for itself.”

The SC’s admonition was in line with Section 14, Article VIII of the Constitution which states: “No decision shall be rendered by any court without expressing therein clearly and distinctly the facts and the law on which it is based.”

The CA’s reminder to trial court judges was contained in the case appealed by two members of the Kaunlaran ng Magsasaka, Inc. (KMI), a domestic non-governmental organization set up to facilitate credit development for the peasantry.

It ruled in favor of the KMI members who challenged the ruling of the Quezon City regional trial court (RTC) in a collection suit filed by the government through the Department of Agrarian Reform (DAR).

Case records showed that the government in 1993 allocated a budget for the Peasant Development Fund (PDF) for agrarian reform programs and social reform agenda.

Thereafter, DAR tasked KMI to implement the disbursement of funds to farmers via Memorandum of Agreements (MOAs).

Under the MOA, P32 million was lent by DAR to KMI on July 22, 1993 with interest of one per cent yearly and payable in 45 years from 1999.

The second MOA in 1994 stated that P64.8 million was released to KMI with the same terms and conditions contained in the first agreement.  A total of P986,761.35 was to be deducted for first amortization on the previous loan.

In both MOAs, KMI undertook to submit quarterly project status and financial reports to DAR on projects approved and funded from P97.2 million PDF.

In 2009, the DAR filed a complaint after KMI, represented by its chairman Alejandro Asis, failed to comply with the MOAs despite repeated demands. It pointed out that KMI made no payments except the P986,761.35  that was deducted from loan contained in the second MOA.

DAR also said that while KMI sought to restructure the loan, the latter did not pursue the restructuring and did not make any further payments except for another P100,000.

On Dec. 13, 2011, DAR amended its complaint to include KMI trustees Antonio Austria, Vicente Jayme, Flaviano Encinares, Rodrigo Villaflor, Sr., Andres Montejo, Gregorio Nazarres, Joseph B. Banghulot, Laurentino Bascug, Norberto B. Gonzales, Juan C. Tan, and Fr. Antonio Olaguer, S.J.

Seven years from the filing of the complaint in 2009 and after resolving numerous motions and counter-pleadings lodged by the parties, the RTC rendered its decision on Dec. 29, 2016.

The RTC’s decision was in favor of DAR as the trial court directed the defendants to solidarily pay the loan of P96.1 million with one per cent interest yearly and 10 per cent of the total amount due as attorney’s fees and collection charges.

KMI and its trustees elevated the case to the CA. Among other things, they asked the CA “whether or not the 29 December 2016 Judgment is valid considering that it is bereft of clear and distinct facts and the law on which it is based.”

Citing an SC decision, the CA said:

“Judicial and quasi-judicial officials are constitutionally mandated to distinctly state the factual and legal bases of their decisions. This must be so to conform with the requirement of due process and fair play because parties in a controversy should be informed of why and how such decisions were reached.”

It said the assailed RTC decision was contained in three pages “with the first two pages containing a recitation of the facts of the case and the third page indicating the RTC's finding and ruling….”

The CA ruled: “WHEREFORE, the appeal is GRANTED. The 29 December 2016 Judgment of the Regional Trial Court, Branch 96, Quezon City, in Civil Case No. Q-09-65778 is SET ASIDE. The case is REMANDED to the court a quo for rendition of judgment that is in accordance with the mandate of Section 14, Article VIII of the Constitution and the evidence on record. No costs.”

Associate Justices Myra V. Garcia Fernandez and Bonifacio S. Pascua concurred in the decision.