G.R. No. 215280, November 27, 2019
FRANCISCO C. EIZMENDI, JR., JOSE S. TAYAG, JR., JOAQUIN L. SAN AGUSTIN, EDUARDO V. FRANCISCO, EDMIDIO V. RAMOS, JR., ALBERT G. BLANCAFLOR, REY NATHANIEL C. IFURUNG, MANUEL H. ACOSTA, JR., AND VALLE VERDE COUNTRY CLUB, INC., PETITIONERS, V. TEODORICO P. FERNANDEZ, RESPONDENT.

FACTS

This case resolves a Motion for Reconsideration filed by respondent Teodorico P. Fernandez, seeking to set aside the Supreme Court’s Decision dated September 5, 2018. The assailed Decision had granted the petition for review, reversed the Court of Appeals, and reinstated an Order from the Regional Trial Court (RTC) of Pasig City, Branch 158, in Commercial Case No. 13-202. The RTC Order did not allow the presentation of evidence relating to the February 23, 2013 elections of the Board of Directors of Valle Verde Country Club, Incorporated (VVCCI). Fernandez’s complaint questioned the suspension of his VVCCI membership, alleging lack of authority of the petitioners (who were acting as directors) and denial of due process. The Supreme Court’s earlier Decision found that Fernandez’s complaint was partly an election contest, filed beyond the 15-day reglementary period under the Interim Rules of Procedure for Intra-Corporate Controversies (Interim Rules), and thus barred. In his Motion for Reconsideration, Fernandez argued that the Court erred in applying the principle of stare decisis based on a prior unsigned (minute) resolution in a related case, Valle Verde Country Club, Inc. v. Eizmendi, Jr., et al. (G.R. No. 209120). He contended that such a resolution does not constitute a binding precedent, that the discussions on “election contest” in that case were mere obiter dicta, and that the reglementary period should not apply to him as he was not a candidate and had no cause of action during that period.

ISSUE

Whether the Supreme Court erred in denying Fernandez’s Motion for Reconsideration, specifically in: (1) applying the stare decisis principle based on an unsigned minute resolution from a prior case (Valle Verde, G.R. No. 209120) to classify his complaint as an election contest; and (2) consequently ruling that his action, being partly an election contest, was filed beyond the 15-day reglementary period and thus barred.

RULING

The Supreme Court DENIED the Motion for Reconsideration for lack of merit.
1. On the Binding Precedent of the Minute Resolution: The Court held that the unsigned resolution in Valle Verde (G.R. No. 209120) could serve as a binding precedent in this case. It clarified that while a minute resolution may not constitute a binding precedent for different parties or subject matters, it can establish a precedent when it clearly and distinctly states the facts and law upon which it is based, and is not merely a dismissal for procedural deficiencies. The Court found that the Valle Verde resolution directly resolved the substantive issue of what constitutes an election contest under the Interim Rules, applying Section 2, Rule 6. It explicitly ruled that a complaint raising issues of proxy validation and the manner and validity of elections falls under the definition of an election contest. This ruling was not obiter dictum (an incidental remark) but was central to the disposition of that case.
2. On the Nature of Fernandez’s Complaint as an Election Contest: The Court affirmed its earlier finding that Fernandez’s complaint was partly an election contest. It reiterated that under Section 2, Rule 6 of the Interim Rules, an election contest includes any dispute involving the validation of proxies and the manner and validity of elections. By questioning the authority of the petitioners as directors—which authority stemmed from the February 23, 2013 election—Fernandez’s complaint inherently sought to assail the validity of that election. The Court also noted that the reliefs prayed for in his complaint, which included declarations on the invalidity of the election and the proxies, supported this classification. The reglementary 15-day period for filing election contests is mandatory. The Court rejected Fernandez’s argument that the period did not apply to him because he was not a candidate, stating that the prohibition on indirectly attacking an election after the reglementary period had lapsed applies regardless.
3. On the Prayer for Relief: The Court rejected Fernandez’s argument that the prayer in his complaint should be disregarded. It ruled that the prayer for relief is an integral part of a pleading under the Rules of Civil Procedure and can be considered in determining the nature of the cause of action.
Consequently, the Supreme Court found no error in the RTC’s order barring the presentation of evidence on the February 23, 2013 elections, as Fernandez’s first cause of action was essentially an election contest filed out of time.