SJS, a registered political party, sought the interpretation of several constitutional provisions, specifically on the separation of church and state; and a declaratory judgment on the constitutionality of the acts of religious leaders endorsing a candidate for an elective office, or urging or requiring the members of their flock to vote for a specified candidate.
The subsequent proceedings were recounted in the challenged Decision in these words:
“x x x. Bro. Eddie Villanueva submitted, within the original period [to file an Answer], a Motion to Dismiss. Subsequently, Executive Minister Eraño Manalo and Bro. Mike Velarde, filed their Motions to Dismiss. While His Eminence Jaime Cardinal L. Sin, filed a Comment and Bro. Eli Soriano, filed an Answer within the extended period and similarly prayed for the dismissal of the Petition. All sought the dismissal of the Petition on the common grounds that it does not state a cause of action and that there is no justiciable controversy. They were ordered to submit a pleading by way of advisement, which was closely followed by another Order denying all the Motions to Dismiss. Bro. Mike Velarde, Bro. Eddie Villanueva and Executive Minister Eraño Manalo moved to reconsider the denial. His Eminence Jaime Cardinal L. Sin, asked for extension to file memorandum. Only Bro. Eli Soriano complied with the first Order by submitting his Memorandum.
The Court denied the Motions to Dismiss, and the Motions for Reconsideration filed by Velarde, Villanueva and Manalo, which raised no new arguments other than those already considered in the motions to dismiss.
The trial court said that it had jurisdiction over the Petition, because “in praying for a determination as to whether the actions imputed to the respondents are violative of Article II, Section 6 of the Constitution, [the Petition] has raised only a question of law.” It then proceeded to a lengthy discussion of the issue raised in the Petition – the separation of church and state – even tracing, to some extent, the historical background of the principle. Through its discourse, the court a quo opined at some point that the “endorsement of specific candidates in an election to any public office is a clear violation of the separation clause.”
After its essay on the legal issue, however, the trial court failed to include a dispositive portion in its assailed Decision. Thus, Velarde and Soriano filed separate Motions for Reconsideration which, as mentioned earlier, were denied by the lower court.
What is the standard form of a Decision? Did the challenged Decision comply with the aforesaid form?
No. The challenged Decision did not comply with the proper form of a Decision.
In general, the essential parts of a good decision consist of the following:
(1) statement of the case; (2) statement of facts; (3) issues or assignment of errors; (4) court ruling, in which each issue is, as a rule, separately considered and resolved; and, finally, (5) dispositive portion. The ponente may also opt to include an introduction or a prologue as well as an epilogue, especially in cases in which controversial or novel issues are involved.
Indeed, the assailed Decision was rendered in clear violation of the Constitution, because it made no findings of facts and final disposition. Hence, it is void and deemed legally inexistent. Consequently, there is nothing for this Court to review, affirm, reverse or even just modify.
Failure to comply with the constitutional injunction is a grave abuse of discretion amounting to lack or excess of jurisdiction. Decisions or orders issued in careless disregard of the constitutional mandate are a patent nullity and must be struck down as void. Indeed, the RTC’s Decision cannot be upheld for its failure to express clearly and distinctly the facts on which it was based. Thus, the trial court clearly transgressed the constitutional directive.