Practice question
A litigant cites De los Santos’s pending-action principle as an automatic command to reopen every judgment already conclusively final, without identifying any independent lawful reopening ground. Which is sound?
- Every procedural amendment necessarily revives every closed case.
- The stated pending-and-undetermined principle does not itself supply that universal reopening command.
- The decisions abolish all finality rules.
- A party may reopen a final case by merely renaming it pending.
- The pending-action qualification has no meaning.
Legal references
- Spouses De los Santos v. Vda. de Mangubat, G.R. No. 149508, October 10, 2007, main decision, remedial law and pending actions: https://lawphil.net/judjuris/juri2007/oct2007/gr_149508_2007.html
- Fil-Estate Properties, Inc. v. Homena-Valencia, G.R. No. 173942, June 25, 2008, operative reconsideration resolution, retroactive procedural application: https://lawphil.net/judjuris/juri2008/jun2008/gr_173942_2008.html
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