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Friday, April 19, 2013

Oil and Natural Gas Commission v. CA


Oil and Natural Gas Commission v. CA
G.R. No. 114323 July 23, 1998
Martinez, J.

Issue:

                whether or not Memorandum Decisions are violative of Section 14, Article VIII of the Constitution

Held:

                No. The constitutional mandate that no decision shall be rendered by any court without expressing therein dearly and distinctly the facts and the law on which it is based does not preclude the validity of “memorandum decisions” which adopt by reference the findings of fact and conclusions of law contained in the decisions of inferior tribunals.

Even in this jurisdiction, incorporation by reference is allowed if only to avoid the cumbersome reproduction of the decision of the lower courts, or portions thereof, in the decision of the higher court. This is particularly true when the decision sought to be incorporated is a lengthy and thorough discussion of the facts and conclusions arrived at.



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