Case Summary (G.R. No. 159357)
Procedural Deficiencies in the SJS Petition
– No justiciable controversy: SJS alleged only speculative or hypothetical future endorsements, without any imminent or actual act by respondents threatening its rights.
– No cause of action: The petition did not arise from any deed, contract, statute or regulation affecting a specific legal interest; it merely posed a legal question.
– No legal standing: SJS failed to allege how its members’ rights or privileges would be directly injured or threatened by any endorsement. Its asserted “keen interest” was impersonal and too vague.
Standing and Justiciability
Under Rule 63 and established jurisprudence, declaratory relief requires (1) an existing case or controversy; (2) adverse interests; (3) a legal interest of the petitioner; and (4) ripeness for judicial determination. SJS satisfied none. Merely seeking an advisory opinion on a constitutional principle is beyond judicial power.
Proper Procedural Requirements Before the Trial Court
Civil and special civil actions must begin with a pleading stating ultimate facts and relief sought; summons must issue; defendants must answer; motions to dismiss must be heard with reasons stated; issues must be joined; and pretrial and trial procedures observed. Here, the RTC:
– Accepted a deficient petition without factual allegations or relief prayer;
– Denied motions to dismiss without hearing or reason;
– Ignored joinder of issues and notice to the Office of the Solicitor General;
– Rendered its Decision before resolution of pending motions and without answers.
These irregularities constituted grave abuse of discretion.
Constitutional and Rule-based Requirements for Decisions
The 1987 Constitution (Art. VIII, Sec. 14) and Rule 36, Sec. 1 require every decision to be in writing, personally prepared by the judge, and to state “clearly and distinctly the facts and the law on which it is based,” and to include a dispositive portion. Administrative Circular No. 1 (1988) and repeated SC decisions (e.g., Yao v. CA) emphasize that failure to comply renders a decision void. The RTC Decision contained neither factual findings nor a dispositive clause—merely “SO ORDERED”—and thus was legally nonexistent.
Substantive Issue on Religious Endorsements
Although the constitutionality of religious endorsements is of paramount public importance, SJS’s petition and the RTC record offered no concrete factual basis or threat to justify adjudic
Case Syllabus (G.R. No. 159357)
Facts and Procedural Posture
- Respondent Social Justice Society (SJS), a registered political party, filed on January 28, 2003 a Petition for Declaratory Relief (Civil Case No. 03-105642, RTC-Manila, Branch 49)
- SJS prayed for interpretation of constitutional provisions on the separation of church and state and for a declaration on the constitutionality of religious leaders endorsing candidates or urging their followers’ votes
- RTC-Manila issued a June 12, 2003 Decision and a July 29, 2003 Order denying motions for reconsideration, which lacked a statement of facts and a dispositive portion
- Brother Mike Velarde filed a Petition for Review under Rule 45 assailing both the June 12, 2003 Decision and the July 29, 2003 Order
RTC Proceedings and Deficiencies
- Co-respondents Villanueva, Manalo and Velarde filed Motions to Dismiss; Cardinal Sin filed a Comment; Soriano filed an Answer and a Motion for Reconsideration
- RTC denied all Motions to Dismiss without stating grounds or reasons, and directed submission of memoranda
- RTC rendered its “Decision” without hearing pending motions, without joinder of issues, without notifying the Office of the Solicitor General, without factual findings, and without a dispositive clause
- Motions for Reconsideration by Velarde and Soriano were denied; Velarde elevated the case to the Supreme Court
Issues Presented to the Supreme Court
- Whether the RTC Decision of June 12, 2003 was proper and valid
- Whether a justiciable controversy existed in SJS’s Petition
- Whether SJS had legal interest and standing to file the Petition for Declaratory Relief
- Whether the constitutional question was ripe for judicial determination
- Whether adequate remedies other than declaratory relief existed
- Whether RTC-Manila had jurisdiction over SJS’s Petition
Procedural Requirements for Declaratory Relief
- Rule 63, Section 1: Petitioner must be interested under a written instrument or affected by a statute/regulation and seek construction or validity
- Essential requisites:
- Existence of a justiciable controversy
- Adverse legal interests between parties
- Legal interest of petitioner in the controversy
- Ripeness of the issue