Title
Ramos vs. Central Bank of the Philippines
Case
G.R. No. L-29352
Decision Date
Feb 19, 1986
Central Bank's third motion for reconsideration denied; Court upheld finality of 1982 Resolution, barring further clarification or reconsideration.

Case Digest (G.R. No. L-29352)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • The case involves Emerito M. Ramos, et al., petitioners, versus the Central Bank of the Philippines, respondent.
    • The petitioners had been involved in a series of motions related to clarificatory rulings and motions for reconsideration pertaining to earlier resolutions.
  • Motions and Resolutions
    • The respondent Central Bank filed a Motion for Clarificatory Ruling and/or Third Motion for Reconsideration on February 4, 1986, attached to its previous motions.
    • These motions were in relation to the Courts’ resolutions dated:
      • October 19, 1982 – The original per curiam resolution, subsequently approved by a full Court composed of fourteen members.
      • July 22, 1985 – The first motion for reconsideration which was denied for lack of necessary votes.
      • January 21, 1986 – The second motion for reconsideration which was likewise denied.
    • Entry of judgment on the said resolution (October 19, 1982) was effected on January 30, 1986.
  • Judicial Composition and Procedural History
    • The original resolution from October 19, 1982 was approved by the full Court at that time, which then had fourteen members.
    • Of these fourteen members, six (namely, Fernado, Makasiar, Guerrero, De Castro, Vasquez, and Relova) had retired at the time the present motions were considered.
    • The denied motions (first and second reconsideration motions) did not secure the needed votes for approval, reinforcing the finality of the earlier decision.
  • Dissenting Opinion
    • Associate Justice Aquino, Chief Justice in dissent, expressed his disagreement with the denial of the third motion for reconsideration by the Court.
    • Justice Aquino based his dissent on the precedent set in Vir-jen Shipping and Marine Services, Inc. vs. National Labor Relations Commission (125 SCRA 577), where a third motion for reconsideration was entertained.
    • He noted that:
      • The first motion for reconsideration was denied in the resolution of September 29, 1982.
      • The second was denied in the resolution of December 20, 1982.
      • A third motion was then admitted and eventually granted in the resolution of November 18, 1983.
    • Justice Aquino incorporated the Central Bank’s third motion for reconsideration as Annex 1 in his dissent, emphasizing his view that such a motion should be considered based on established precedent.

Issues:

  • Admissibility of Subsequent Motions
    • Whether the filing of a third motion for reconsideration and a clarificatory ruling should be permitted given the procedural history of the case.
    • Whether the resolution of October 19, 1982 already being final precludes any further motions for clarification or reconsideration.
  • Consistency With Precedent
    • The issue of whether previous decisions, particularly the denial of the first and second motions for reconsideration, establish a rule that disallows a third motion for reconsideration.
    • The extent to which the precedent set in Vir-jen Shipping and Marine Services, Inc. vs. National Labor Relations Commission should influence the Court’s decision.
  • Clarification of the Court’s Previous Rulings
    • Whether there is any ambiguity or inconsistency in the earlier rulings that would justify a clarificatory ruling.
    • If further elucidation on the prior decisions is necessary to address the parties’ concerns.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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