The constitutional requirement that every decision must state distinctly and clearly the factual
and legal bases therefor should indeed be the primordial concern of courts and judges. Be that as
it may, there should not be a mechanical reliance on this constitutional provision. The courts and
judges should be allowed to synthesize and to simplify their decisions considering that at present,
courts are harassed by crowded dockets and time constraints. Thus, the Court held in Del Mundo
v. Court of Appeals:
It is understandable that courts with heavy dockets and time constraints, often find themselves
with little to spare in the preparation of decisions to the extent most desirable. We have thus
pointed out that judges might learn to synthesize and to simplify their pronouncements.
Nevertheless, concisely written such as they may be, decisions must still distinctly and clearly
express at least in minimum essence its factual and legal bases. xxviii[28]
In Nicos Industrial Corporation v. Court of Appeals,xxix[29] the Court states the reason for the
constitutional requirement thus:
It is a requirement of due process that the parties to a litigation be informed of how it was
decided, with an explanation of the factual and legal reasons that led to the conclusions of the
court. The court cannot simply say that judgment is rendered in favor of X and against Y and just
leave it at that without any justification whatsoever for its action. The losing party is entitled to
know why he lost, so he may appeal to a higher court, if permitted, should he believe that the
decision that does not clearly and distinctly state the facts and the law on which it is based leaves
the parties in the dark as to how it was reached and is especially prejudicial to the losing party,
who is unable to pinpoint the possible errors of the court for review by a higher tribunal.xxx[30]
Under Art. X, Sec. 9 of the 1973 Constitution that contained a provision similar to Art. VIII, Sec.
14 of the present Constitution, the Court expresses in Bernabe v. Geraldez the following
rationale as to the wide discretion enjoyed by a court in framing its decision:
x x x In the x x x case of Mendoza v. Court of First Instance of Quezon City, (L-5612, June 27,
1973, 51 SCRA 369) citing Jose v. Santos, (L-25510, October 30, 1970, 35 SCRA 538) it was
pointed out that the standard expected of the judiciary is that the decision rendered makes clear
why either party prevailed under the applicable law to the facts as established. Nor is there any
rigid formula as to the language to be employed to satisfy the requirement of clarity and
distinctness. The discretion of the particular judge in this respect, while not unlimited, is
necessarily broad. There is no sacramental form or words which he must use upon pain of being
considered as having failed to abide by what the Constitution directs. (51 SCRA 369 at
375)xxxi[31]
After careful reflection, this Court finds that the questioned decision of the court a quo explained
the factual findings and legal justifications, at least in minimum essence, which led to the
conviction of accused-appellant. Thus, the subject decision of Judge Baltazar Relativo Dizon,
after quoting the information for Illegal Recruitment and stating accuseds plea of not guilty, goes
on to summarize the evidence for the prosecution and the defense as testified to by their
respective witnesses. Before drawing a conclusion, it gives an ANALYSIS OF EVIDENCE ON
RECORD as follows: