GR L 3983; (February, 1910) (Digest)
G.R. No. L-3983
February 15, 1910
SALVADORA OCAMPO, ET AL., plaintiffs-appellees, vs. TOMAS CABAÑGIS, defendant-appellant.
FACTS:
On December 26, 1908, a judgment was entered in this case stating, “Without prejudice to the filing of an extended opinion later, the judgment appealed from is hereby reversed and the defendant is absolved from the complaint without special finding as to costs…” No further or extended decision was ever filed. Two of the four justices who signed the original decision are no longer members of the Supreme Court. The appellees subsequently filed a motion seeking the cancellation and annulment of the entry of judgment and the recall of the remittitur and the record of the case. They argued that no final judgment had ever been entered because the contemplated “extended opinion” was never filed, and it could not be filed now due to changes in the court’s personnel. They implicitly referred to Section 15 of Act No. 136 , which mandates that “all decisions of the Supreme Court shall be given in writing, signed by the judges concurring in the decision, and the grounds of the decision shall be stated as briefly as may be consistent with clearness.” The original decision was in writing and signed, but it did not state the grounds.
ISSUE:
Whether the failure of the Supreme Court to state the grounds of its decision, as required by Section 15 of Act No. 136 , renders the judgment invalid and not final, especially when an extended opinion was promised but never filed.
RULING:
The Supreme Court denied the motion, ruling that the judgment entered on December 26, 1908, was valid and final.
The Court held that Section 15 of Act No. 136 , requiring decisions to state the grounds, is directory rather than mandatory. While it is desirable for appellate courts to state the reasons for their decisions for clarity and certainty, compliance with this procedural statute is not essential to the validity of a duly and formally rendered decision. The Court reasoned:
1. Nature of Procedural Statutes: Legislatures often enact statutes for orderly procedure, but procedure is secondary to substantive rights. Non-observance of such procedure should not affect substantive rights unless clearly expressed as the legislative intent.
2. Impracticability and Impossibility: Strict and literal compliance with such a statute could often render it impossible for the court to decide a case. It is not unusual for a majority of judges to agree on a conclusion while being unable to agree on the exact grounds or reasons. The conclusion of the majority constitutes the decision, regardless of individual reasoning.
3. Judicial Prerogative: The exact form and manner in which decisions shall be rendered are questions of judicial, rather than legislative, determination. Legislatures cannot impose conditions and restrictions that would render courts incapable of performing their functions properly and efficiently, or unreasonably control a constitutional court’s exercise of its judicial functions.
4. Grant of Judicial Power: A grant of judicial power inherently includes all the judicial power that may be exercised under the government, implying that the judiciary determines how it will express its final decisions.
Therefore, the failure to provide the promised extended opinion or to state the grounds in the initial judgment did not invalidate the decision, and the original judgment remained effective.
