Section 14. No decision shall be rendered by any court without expressing therein clearly and distinctly the facts and the law on which it is based.

No petition for review or motion for reconsideration of a decision of the court shall be refused due course or denied without stating the legal basis therefor.


Agoy v. Araneta Center
G.R. No. 196358, March 21, 2012


Facts:

The Court denied Agoy’s petition for review through a minute resolution. Agoy promptly filed a motion to rescind the same and to have his case resolved on its merits via a regular resolution or decision. Someone claiming to be Agoy’s attorney-in-fact also requested an investigation of the issuance of the minute resolution. 

The Court denied Agoy’s motion to rescind the subject minute resolution and confirmed the authenticity of the copy of the resolution. It also treated his motion to rescind as a motion for reconsideration and denied the same with finality.

Agoy filed a motion to rescind the same or have his case resolved by the Court En Banc. Agoy reiterated his view that the Court cannot decide his petition by a minute resolution.


Issue:

Whether or not it was proper for the Court to deny Agoy's petition through a minute resolution.


Held:

While the Constitution requires every court to state in its decision clearly and distinctly the fact and the law on which it is based, the Constitution requires the court, in denying due course to a petition for review, merely to state the legal basis for such denial.

With the promulgation of its Internal Rules, the Court itself has defined the instances when cases are to be adjudicated by decision, signed resolution, unsigned resolution or minute resolution. Among those instances when a minute resolution shall issue is when the Court "denies a petition filed under Rule 45 of the [Rules of Court], citing as legal basis the absence of reversible error committed in the challenged decision, resolution, or order of the court below." The minute resolutions in this case complied with this requirement.

The Court has repeatedly said that minute resolutions dismissing the actions filed before it constitute actual adjudications on the merits. They are the result of thorough deliberation among the members of the Court. When the Court does not find any reversible error in the decision of the CA and denies the petition, there is no need for the Court to fully explain its denial, since it already means that it agrees with and adopts the findings and conclusions of the CA. The decision sought to be reviewed and set aside is correct. It would be an exercise in redundancy for the Court to reproduce or restate in the minute resolution denying the petition the conclusions that the CA reached.