Case Digest

Buaya v. Stronghold Insurance Company, Inc.

As generally used the term law of the case designates the principle that if an appellate court has passed on a
legal question and remanded the cause to the court below for further proceedings, the legal question not
determined by the appellate court will not be differently determined on a subsequent appeal in the same case
where the facts remain the same. Allen v. Michigan Bell Tel. Co., 232 N.W.2d 302, 303. Doctrine which provides
that an appellate court’s determination on a legal issue is binding on both the trial court on remand and an
appellate court on a subsequent appeal given the same case and substantially the same facts. Hinds v. McNair,
413 N.E.2d 586, 607.

Facts:
On July 31, 1985, Stronghold Insurance Company, Inc. filed a complaint against Paquito B. Buaya, a
manager of their Cebu branch for the collection of the principal amount of P678,076.83, which is
allegedly his unremitted premium collections owing to the Stronghold. For failure of Buaya and his
counsel to appear at the pre-trial, he was defaulted and Stronghold was allowed to present his
evidences, without the other party. On the basis of Stronghold’s evidence, the court decided on
September 17, 1987, in favor of Stronghold.

Buaya appealed to the CA, and on March 30, 1990, decided in favor of Buaya, annulling the decision
and remanding the case to the lower court for further proceedings. The lower court therefore set a
hearing on December 13, 1990 but Buaya filed a ‘Motion of Postponement’ of the hearing and was
granted. He repeated his motion and gave several reasons to postpone the hearings. On July 26, 1991,
Stronghold opposed the motion, but the court granted Buaya’s motion provided that the next time he
does it, it will be considered a waiver of his right to present evidence. Stronghold filed a motion to
reinstate its previous decision dated, September 17, 1987. Buaya filed a motion for reconsideration but
was denied. He files a ‘Petition for Certiorari’ assailing the orders of the court but was dismissed for
lack of merit. On June 28, 1993, the court’s decision has became final and executory and thus denied
all other appeals made before it.

Issues:
1. Can a decision of a Regional Trial Court which is annulled by the Court of Appeals be
reinstated by the trial court which rendered the decision or any trial court for that matter and
thereafter order its execution?
2. When the decision of a trial court is annulled by the Court of Appeals for having been rendered
without notice to the Buaya of the pre-trial and subsequent hearing and remanded to the court of
origin for further proceedings, does the jurisdiction of the trial court merely require the
presentation of evidence for Buaya and without anymore requiring the presentation of
Stronghold’s evidence for cross-examination by the Buaya?

Ruling: This petition has no merit. DENIED.

Ratio:
1. Annulled Decision: The decision of the trial court was annulled by the CA, because his Appeal
Brief stated that it had merely been set aside. This shows that the trial court's Decision was
reversed and set aside, not annulled, by the appellate court. Since it was merely set aside to
enable petitioner to present his evidence, then there was nothing wrong with the Order of the
trial court reinstating its original decision after he had failed to take advantage of the ample
opportunity given him to present evidence. An authentic copy thereof should have been
 submitted to support his claim that the Decision of the trial court had indeed been annulled by
that of the CA. Hence, a copy of the latter is a "material portion of the record [that] would
support the petition." Failure to attach or submit it is sufficient ground for this Petition's
dismissal.
2. Final and Executory Judgment: Once a judgment becomes final and executory, the prevailing
party can have it executed as a matter of right, it is axiomatic that once a decision attains
finality, it becomes the law of the case regardless of any claim that it is erroneous. Having been
rendered by a court of competent jurisdiction acting within its authority, the judgment may no
longer be altered even at the risk of occasional legal infirmities or errors it may contain.
Litigations must end and terminate sometime and somewhere. The effective and efficient
administration of justice requires that once a judgment has become final, the prevailing party
should not be deprived of the fruits of the verdict by subsequent suits on the same issues filed
by the same parties.