G.R. No. 193034 - Reyes vs. People

Petitioner Rodging Reyes was charged with Grave Threats arising from a complaint filed by private respondent Salud M. Gegato.
The alleged offense occurred on or about October 16, 2001, at approximately 5:10 p.m. at Avon Store, located on Atis Street, Poblacion, Bayugan, Agusan del Sur.
The charge was based on the explicit threat uttered by the petitioner via telephone, which conveyed the message: “Salud, undanga ang imong pagsigi ug tsismis sa akong asawa, kay maulawan ang akong asawa. Warningan taka ayaw pang hilabot sa among kinabuhi kay basin patyon taka,” thereby instilling fear and risk to the life of Mrs. Gegato.
The complaint alleged that the petitioner’s deliberate statement, motivated by personal resentment and hatred, was intended to cause actual, moral, and compensatory damages to the victim.

Before arraignment, petitioner filed a Motion to Quash challenging the court’s jurisdiction and arguing that the crime charged did not qualify as Grave Threats under Article 282 of the Revised Penal Code but rather as Other Light Threats under Article 285, paragraph 2.
The Municipal Circuit Trial Court (MCTC) of Bayugan and Sibagat, Agusan del Sur, denied the motion on June 3, 2002, and again denied the petitioner’s motion for reconsideration on July 25, 2002.
Subsequently, on September 13, 2002, petitioner filed a Motion to Inhibit the presiding judge on the ground that private respondent Salud Gegato functioned as the Court Interpreter in the same court. This motion was denied on September 16, 2002, with reference to an earlier Supreme Court order clarifying that the ground cited did not fall under the absolute disqualification rule of Section 1, Rule 137 of the Rules of Court.

On August 10, 2005, the MCTC rendered its Decision finding petitioner guilty beyond reasonable doubt of the crime of Grave Threats, imposing a sentence within the medium period of arresto mayor (ranging from two months and one day to four months) with a condition that the offender did not attain his threatening purpose.
The ruling also required the petitioner to pay:

ONE HUNDRED THOUSAND Pesos (P100,000.00) as moral damages to the private complainant.
TWENTY THOUSAND Pesos (P20,000.00) for litigation expenses and attorney’s fees, noting that the complainant was assisted by a private prosecutor.

Petitioner appealed the MCTC decision. On April 2, 2007, the RTC confirmed the petitioner’s guilt—albeit reclassifying the charge as Other Light Threats under Article 285, paragraph 2 of the Revised Penal Code.
The RTC modified the sentence, imposing:

Imprisonment of 10 days of arresto menor.
A reduction in moral damages from the original P100,000.00 to P50,000.00 initially, which was further reduced upon a subsequent motion for reconsideration.

On May 16, 2007, following a Motion for Reconsideration, the RTC modified its decision by reducing the amount of moral damages to P10,000.00 and attorney’s fees to P10,000.00.

Petitioner sought to file a Petition for Review in the Court of Appeals (CA) by initially filing a Motion for Extension of Time.

The petitioner’s first motion for extension (15 days from June 6, 2007) was denied due to incomplete payment of the docket fees.
A second extension motion was also denied on the grounds that further extension was not permissible except for the most compelling reasons.

It was filed beyond the reglementary period.
There was a failure to pay the full amount of docket fees, with a deficiency of P3,530.00.
The petition lacked a complete statement of material dates, notably omitting the date when the petitioner received the RTC’s Order dated May 16, 2007.
It did not include pertinent documentary attachments, such as the copy of the May 16, 2007 Order.

A third Motion for Reconsideration was filed on August 14, 2007 and later another on November 13, 2008.
The CA granted the petitioner’s second Motion for Reconsideration in its Resolution dated November 23, 2009, thereby setting aside its previous Resolution dated October 17, 2008, while simultaneously dismissing the petition for review with finality.
A subsequent third Motion for Reconsideration filed on December 28, 2009 was merely noted without action by the CA on June 24, 2010.

Petitioner contended that the CA excessively favored procedural technicalities over his constitutional right to due process.
He argued that his repeated filing of motions for reconsideration should toll the running reglementary period for filing a petition for review.
The petitioner further requested leniency based on the need to unclog court dockets and the principle that genuine disputes should be resolved on their merits rather than dismissed on technicalities.
The Office of the Solicitor General (OSG) and relevant precedents were cited, emphasizing that delayed pleadings which are procedurally prohibited cannot toll the appeal period.

The Supreme Court underscored the inviolate nature of certain procedural rules, particularly that second and subsequent motions for reconsideration are generally disallowed under Section 2, Rule 52 of the Rules of Court.
It reiterated that technical defaults, such as nonpayment of the full docket fee and failure to include necessary attachments and statements, were sufficient grounds for dismissal.
The Court affirmed the principle that only errors of law—not of fact—are reviewable in a petition for review on certiorari under Rule 45.
Referencing several precedents and doctrines, the Court stressed that permitting repeated motions for reconsideration would disrupt the finality of judgments and encourage procedural irregularities.

Whether the CA erred in dismissing the petitioner’s petition for review on the basis of several procedural infirmities, including late filing, incomplete payment of docket fees, deficient statement of material dates, and lack of pertinent attachments.
Whether the petitioner’s successive motions for reconsideration, including the second and third motions, could toll the running of the reglementary period for filing a petition for review.

Whether the strict application of Rule 42 (regarding the payment of docket fees and submission requirements) and Rule 52 (prohibiting second or subsequent motions for reconsideration) should be relaxed in light of the petitioner’s argument that his constitutional right to due process was compromised.
Whether the granting of an extension for filing a petition for review, under the circumstances presented, could be justified by a compelling reason to prevent a grave injustice.

Whether the errors alleged by the petitioner, particularly regarding the reclassification of the crime from Grave Threats to Other Light Threats, should be subject to review given that the Supreme Court’s purview under Rule 45 is limited to errors of law.