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GEORGE YAO V.

COURT OF APPEALS
October 24, 2000 | Davide, Jr., J.
Judicial Department > Supreme Court > Requirements as to Decisions
AKGL

DOCTRINE: Faithful adherence to the requirements of Sec. 14, Art. 8 is a paramount component of due process and fair play. It also
informs the losing party why he lost, so he may appeal to the higher court, if permitted. Lastly, it is an assurance that, in reaching
judgment, the judge did so through legal reasoning.
CASE SUMMARY: PEMCO filed a case against Yao for unfair competition before the MeTC, which ruled in favor of PEMCO. Yao
appealed before the RTC, which dismissed the case but merely quoted the dispositive portion of the MeTC decision. Yao, then
appealed to CA, which also dismissed the petition due to procedural issues. Lastly, Yao appealed to the SC, which granted the petition
because the RTC decision did not comply with CONST, art. 8, sec. 14.

FACTS:
 Philippine Electrical Manufacturing Company (PEMCO) is the only local subsidiary of GE-USA. It is also the only
accredited distributor of GE lamp starters. In June 1990, PEMCO noticed the proliferation of GE lamp starter despite no GE
started was locally manufactured or imported since 1983. Thus, it conducted a market research and found out that Tradeway
Commercial Corporation (TCC) was the source of the GE lamp starter. They filed charges for unfair competition before
MeTC Caloocan against George Yao, the President and General Manager of TCC, and Roxas, who was acquitted eventually.
PEMCO alleged that the GE lamps starters were counterfeit.
 MeTC ruled in favor of PEMCO and convicted Yao of unfair competition and sentenced him of imprisonment.
 Yao appealed to the RTC Caloocan, who ordered Yao and the prosecution to file their respective memorandum. Without
waiting for the memorandum of the prosecution, RTC promulgated a decision, where in the judge merely quoted the
dispositive portion of the MeTC and stated that after “going over the evidence on record, the Court finds no cogent
reason to disturb the findings of the Metropolitan Trial Court.”
 Yao appealed before the CA, which dismissed the petition on procedural grounds (e.g., the appellant has not yet filed the brief
and the MR on the RTC decision was only filed in September while the decision was promulgated in July).
 Yao filed the instant petition for review on certiorari with the following arguments:
1. Entry of judgment was improvidently issued in the absence of a final resolution specifically dismissing the appeal
2. Procedural infirmity (i.e., MR was filed beyond the period allowable) has been cured
3. CA denied him due process

ISSUE: W/N CA erred in dismissing the case and remanded the same to the RTC for execution? YES, but because RTC was at fault

RULING:
 The RTC decision affirming the conviction of Yao palpably transgressed CONST, art. 8, sec. 14, which provides “No decision
shall be rendered by any court without expressing therein clearly and distinctly the facts and the law which it is based.
xxx”
 SC has sustained decisions of lower courts despite some of them lacking in terms of clarity, coherence and comprehensibility
as long as they eventually set out the facts and the law. SC also sanctioned the use of memorandum decisions, a specie of
succinctly written decision by appellate courts on the grounds of expediency, practicality, convenience and docket status.
 In Francisco v. Permskul, the SC held that memo decision to be valid, cannot incorporate the findings and the conclusions of
law of the lower court only by remote reference – the challenged decision is not easily and immediately available. It should
actually embody the findings of fact and conclusions of law of the lower court in an annex attached to and made an
indispensable part of the decision.
 In the instant case, the RTC decision failed miserably.
 Faithful adherence to the requirements of Sec. 14, Art. 8 is a paramount component of due process and fair play. It also
informs the losing party why he lost, so he may appeal to the higher court, if permitted. Lastly, it is an assurance that, in
reaching judgment, the judge did so through legal reasoning.
 Hence, the RTC decision in question is struck down.

DISPOSITION: Petition granted, resolution set aside. Case remanded to trial court for further proceedings and rendition of judgment.

NOTES:
 Since the right to appeal is neither a natural right nor a part of due process, it may be exercised only in the manner and in
accordance with the provision of law. Its requirements must be strictly complied with.
 Legal reasoning is important! Haha. :))