Ortigas & Company v. Velasco

G.R. No. 109645, 112564 (March 4, 1996)

Facts:

The case involves a series of legal proceedings initiated by Dolores V. Molina against Manila Banking Corporation (Manilabank) and Judge Tirso Velasco. The core issue arose from Molina's persistent attempts to challenge a decision made by the Court on July 25, 1994, which was subsequently upheld by a resolution denying her motion for reconsideration on January 23, 1995. Despite the finality of this decision, Molina filed a "Motion for Leave to File the Herein Incorporated Second Motion for Reconsideration" on February 27, 1995, which was deemed unauthorized as it was filed without the necessary express leave from the Court.

The Court had previously issued a directive on March 1, 1995, stating that no further pleadings, motions, or papers should be filed except those directly related to the issues involved in the motion for reconsideration regarding the dismissal of the respondent judge. Molina, however, continued to file additional motions, including a motion to refer the cases to the Court En Banc and several motions for reconsideration of prior resolutions, all of which were denied by the Court.

Manilabank subsequently filed a motion to cite Molina for contempt, arguing that her actions constituted a clear defiance of the Court's orders and an attempt to undermine its authority. They asserted that Molina's motions were unmeritorious and aimed solely at delaying the proceedings.

Legal Issues:

1. Whether Molina's repeated filings after the finality of the Court's decision constituted contempt of court.
2. The validity and implications of filing a second motion for reconsideration without express leave from the Court.
3. The authority of the Court to impose sanctions for willful disobedience of its orders.

Arguments:

• Manila Banking Corporation (Manilabank):

  • Argued that Molina's actions were contumacious and demonstrated a clear intention to defy the Court's authority. They contended that her subsequent motions were without merit and had already been resolved by the Court, thus constituting an abuse of the judicial process.
  • Asserted that the repeated motions filed by Molina were barred by the Court's earlier resolutions, which had declared the cases closed and directed that no further pleadings be filed.

• Dolores V. Molina:

  • Contended that her motions were permissible under the Revised Rules of Court and that they raised new legal issues that warranted consideration. She argued that her filings were made before she was aware of the entry of judgment and that there was no manifest refusal to obey the Court's resolutions.
  • Maintained that her second motion for reconsideration presented new issues and should not be considered a violation of the Court's directive against further pleadings.

Court's Decision and Legal Reasoning:

The Court found Molina guilty of contempt for her willful disregard of its resolutions. It emphasized that the finality of a judgment must be respected and that a second motion for reconsideration is generally prohibited unless express leave is granted. The Court reiterated that the denial of a motion for reconsideration signifies that the grounds relied upon have been found to be without merit, and any other grounds not raised are deemed waived.

The Court underscored the importance of finality in judicial decisions, stating that litigation must come to an end to uphold the integrity of the judicial process. It noted that Molina's persistent attempts to challenge the Court's decisions, despite clear directives against further filings, constituted an abuse of the rules and obstructed the administration of justice.

As a consequence, the Court imposed a fine of P1,000 on Molina, with a warning that any future disregard of its orders would result in more severe penalties.

Significant Legal Principles Established:

1. The principle of finality in judicial decisions, which mandates that once a judgment is rendered and a motion for reconsideration is denied, further attempts to challenge the decision are generally not permitted.
2. The prohibition against filing a second motion for reconsideration without express leave from the Court, emphasizing that such motions should not be used to prolong litigation unnecessarily.
3. The authority of the Court to impose sanctions for contempt when a party willfully disobeys its orders, reinforcing the need for compliance with judicial directives to maintain the integrity of the legal system.