GR 159357; (April, 2004) (Digest)
G.R. No. 159357 ; April 28, 2004
Brother MARIANO “MIKE” Z. VELARDE, petitioner, vs. SOCIAL JUSTICE SOCIETY, respondent.
FACTS
Respondent Social Justice Society (SJS) filed a Petition for Declaratory Relief before the Regional Trial Court (RTC) of Manila against petitioner Brother Mariano “Mike” Z. Velarde and other religious leaders. The petition sought a judicial declaration on whether the act of a religious leader in endorsing a political candidate violates the constitutional principle of separation of church and state. The RTC, after denying various motions to dismiss, proceeded to render a Decision dated June 12, 2003. This Decision contained a lengthy discussion on the constitutional issue but notably omitted a statement of facts and, crucially, a dispositive portion. Petitioner Velarde filed a Clarificatory Motion and Motion for Reconsideration, arguing the Decision’s invalidity due to these omissions. The RTC, in its assailed Order, denied the motions, opining that a dispositive portion was unnecessary in a declaratory relief action and that the proper recourse was an appeal to the Supreme Court.
ISSUE
The primary issue resolved by the Supreme Court is whether the RTC Decision, lacking a statement of facts and a dispositive portion, is valid.
RULING
The Supreme Court granted the petition and declared the RTC Decision void and legally inexistent. The Court emphasized that a decision, to be valid, must conform to the mandatory form and substance prescribed by the Constitution, the Rules of Court, and relevant jurisprudence. Specifically, the Court held that every decision must contain a statement of the facts and a dispositive portion. The statement of facts is essential as it constitutes the very foundation upon which the judgment is based, allowing for intelligent review. The dispositive portion is the court’s definitive order, which settles the rights of the parties and from which any execution issues. The RTC’s justification that a dispositive part was unnecessary for declaratory relief was erroneous. The nature of the action does not excuse compliance with these mandatory requirements. Consequently, a decision that fails to include these elements is void for non-compliance with procedural due process and the constitutional mandate that decisions must clearly and distinctly state the facts and the law on which they are based. The Court remanded the case to the RTC for proper proceedings.