G.R. No. 81006 - Francisco vs. Permskul

On May 21, 1984, petitioner Victorino C. Francisco leased his Makati apartment to respondent Winai Permskul for one year at a rental rate of ₱3,000 per month.
As part of the lease contract, the respondent deposited ₱9,000 to cover unpaid rentals or damages (except those due to reasonable wear and tear).
On May 31, 1985, after vacating the premises, the respondent requested a refund of his deposit less ₱1,000 for ten days of additional occupancy post-lease expiration.
The petitioner refused the refund, contending that the lessee owed additional charges, including payments for electricity and water bills and an extra ₱2,500 for repainting the premises to restore them to its original condition.

The respondent filed suit in the Metropolitan Trial Court of Makati, where summary judgment was rendered on October 11, 1985.
The summary judgment ruled in favor of the respondent, holding that the repainting charge was not attributable to him; it ordered the petitioner to refund ₱7,750 (the remaining deposit after deducting water and electricity charges) and awarded ₱1,250 as attorney’s fees plus costs.
The petitioner subsequently appealed, and the Regional Trial Court of Makati, through Judge Jose C. de la Rama, affirmed the judgment in a memorandum decision on January 14, 1987, adopting by reference the findings of the lower court.

The petitioner challenged the memorandum decision rendered by the Regional Trial Court and sustained by the Court of Appeals, arguing it violated Article VIII, Section 14 of the Constitution, which mandates that every decision must state clearly and distinctly the facts and the law on which it is based.
The petitioner contended that adopting the lower court’s decision by reference without restating the findings in full deprived the parties of an adequate explanation of the basis of the decision.
The respondent defended the memorandum decision as authorized under Section 40 of B.P. Blg. 129, citing the precedent set in Romero v. Court of Appeals, and emphasizing the practical need for expeditious resolution of simple cases.

The decision discusses the practical issues of case backlog in the judiciary and the need for speedy dispositions as provided in various constitutional provisions (Bill of Rights on speedy trial and disposition).
It reflects on the purpose of requiring clear findings of fact and law – to inform the parties, allow proper analysis for possible appeal, and build a repository of useful case law.
The memorandum decision is evaluated against the backdrop of judicial expediency versus the fundamental requirement of a well-reasoned decision as mandated by the Constitution.

Whether the application of Section 40 of B.P. Blg. 129, which permits adopting by reference the lower court’s findings of fact and conclusions of law, violates the constitutional mandate of Article VIII, Section 14.
Whether mere incorporation by reference satisfies the requirement of stating clearly and distinctly the factual and legal bases of a decision as required by the Constitution.

Whether the memorandum decision, by not restating the lower court’s findings in full, deprives the parties of a meaningful explanation of the decision’s basis.
Whether the approach of adopting by reference undermines the litigants’ right to understand the grounds for the judgment and to formulate a pertinent appeal.

To what extent a memorandum decision is acceptable as a tool for expediting judicial proceedings in simple, uncontested cases.
Under what conditions a memorandum decision may become constitutionally infirm if it fails to provide immediate and direct access to the lower court’s decision.