Buaya vs. Stronghold Insurance Co., Inc.

The Court held that a remand of a case for further proceedings does not nullify the entire proceedings or require a trial de novo, but merely authorizes the trial court to receive additional evidence; accordingly, a trial court may reinstate its original decision if the party in whose favor the remand was made fails to present evidence. The Court also held that once a judgment reinstating a decision attains finality, it becomes the law of the case and cannot be relitigated in subsequent proceedings.

Respondent Stronghold Insurance Company, Inc. filed a collection complaint against its former branch manager, petitioner Paquito Buaya, for unremitted premium collections amounting to ₱678,076.83. Petitioner was declared in default for failing to appear at pre-trial, and the trial court rendered a decision based solely on respondent's evidence. The Court of Appeals set aside this default decision and remanded the case for further proceedings to afford petitioner the opportunity to present his evidence. Upon remand, petitioner sought multiple postponements due to the death of his counsel, the need to secure new counsel, and illness. The trial court reset the hearing with the condition that further failure to appear would constitute a waiver of his right to present evidence. When petitioner's new counsel filed another motion to postpone, the trial court denied the motion, declared petitioner to have waived his right to present evidence, and reinstated its original default decision.

• Nature: Collection suit for unremitted premium collections.
• Default Judgment: On July 31, 1985, respondent filed a complaint against petitioner. Petitioner failed to appear at pre-trial and was declared in default. The RTC rendered a default decision on September 17, 1987, ordering petitioner to pay the principal sum plus interest, attorney's fees, and costs.
• Remand by CA: Petitioner appealed to the Court of Appeals. On March 30, 1990, the CA set aside the default decision and remanded the case to the RTC for further proceedings.
• Post-Remand Postponements: Upon remand, petitioner filed multiple motions for postponement. The RTC granted initial motions based on the death of petitioner's counsel and the need to secure new counsel. The hearing was reset to November 29, 1991, subject to the condition that failure to appear would be deemed a waiver of the right to present evidence.
• Waiver and Reinstatement: On November 27, 1991, petitioner's new counsel filed another Motion to Postpone. The RTC denied the motion on December 19, 1991, declaring petitioner to have waived his right to adduce evidence. On March 18, 1992, the RTC denied petitioner's Motion for Reconsideration and granted respondent's motion to reinstate the September 17, 1987 Decision.
• Certiorari to CA and SC: Petitioner filed a Petition for Certiorari with the CA assailing the RTC orders. The CA dismissed the petition on August 24, 1992. Petitioner elevated the case to the Supreme Court, which dismissed the petition. The CA decision became final and executory on June 28, 1993.
• Execution and Petition for Relief: The RTC issued an Order directing the issuance of a Writ of Execution on October 29, 1993. Petitioner's Motion for Reconsideration was denied on March 16, 1995, and his Notice of Appeal was declined due course on May 11, 1995. A Writ of Execution was issued on June 2, 1995. Petitioner filed a Petition for Relief from Order on July 27, 1995, which the RTC denied on November 13, 1995.
• Appeal of Petition for Relief Denial: Petitioner appealed the denial of the Petition for Relief to the CA. The CA dismissed the appeal on August 28, 1998, prompting the present Petition for Review on Certiorari.

• Petitioner argued that a trial court cannot reinstate a decision that has been annulled by the Court of Appeals, claiming such a decision is "dead" in legal contemplation.
• Petitioner contended that a remand for further proceedings requires both parties to present their respective evidence subject to cross-examination, essentially a trial de novo, rather than merely allowing the defendant to present evidence while the plaintiff's prior ex parte evidence stands.

• Respondent argued that the validity of the RTC's reinstatement of its original decision had already been affirmed by the CA and the Supreme Court in prior proceedings, thus petitioner is barred from relitigating the issue.
• Respondent maintained that the CA remand was for further proceedings, not a trial de novo, and because respondent had already rested its case, the remand was solely to afford petitioner the opportunity to present his evidence, which he waived through repeated postponements.

• Procedural Issues:
  • Whether the validity of the trial court's reinstatement of its original decision can be relitigated given that the prior CA decision affirming such reinstatement had already become final and executory.
• Substantive Issues:
  • Whether a trial court may reinstate a decision that was previously set aside and remanded by the Court of Appeals for further proceedings.
  • Whether a remand for further proceedings requires a trial de novo where both parties must present evidence anew, or merely authorizes the reception of additional evidence from the party in whose favor the remand was made.

• Procedural: The Court ruled that the prior CA decision affirming the RTC's reinstatement of its original decision had attained finality. The Supreme Court's February 24, 1993 Resolution in G.R. No. 108354 barred not only a rehash of the same issues but also any other issues that might have been raised. Once a judgment becomes final and executory, it is conclusive of the rights of the parties, and courts will refuse to reopen what has been decided with finality. Petitioner's attempt to relitigate the validity of the reinstated decision constituted a dilatory practice designed to evade the operation of a final and executory judgment.
• Substantive: The Court ruled that the CA decision merely set aside the default judgment to enable petitioner to present his evidence, not to annul it entirely. Because the remand was for further proceedings and not a new trial, the trial court did not err in reinstating its original decision after petitioner failed to take advantage of the opportunity to present evidence. The Court held that the remand did not nullify the entire proceedings; it merely authorized the trial court to receive additional evidence, not to conduct a trial de novo. Because respondent had already rested its case prior to the original default judgment, it was not required to present its evidence again upon remand.

• Finality of Judgments — Once a decision attains finality, it becomes the law of the case regardless of any claim that it is erroneous. A judgment rendered upon the merits, without fraud or collusion, by a court of competent jurisdiction is conclusive of the rights of the parties and their privies. The Court applied this doctrine to bar petitioner from relitigating the validity of the RTC's reinstatement of its original decision, which had already been affirmed with finality by the CA and the Supreme Court in prior proceedings.
• Remand for Further Proceedings — The remand of a case does not nullify the entire proceedings. It merely authorizes the trial court to receive additional evidence, not to conduct a trial de novo. The Court applied this doctrine to hold that the CA's remand was solely to afford petitioner the opportunity to present his evidence, and respondent was not required to present its evidence anew because it had already rested its case.
• Reinstatement of Set-Aside Default Judgment — A trial court may reinstate its original decision after the defaulting party fails to take advantage of the ample opportunity given upon remand to present evidence. The Court held that because the CA decision merely set aside the default judgment to enable petitioner to present evidence, there was nothing wrong with the RTC reinstating its original decision when petitioner waived his right to present evidence through repeated postponements.

• "Courts are duty-bound to put an end to controversies. Any attempt to prolong, resurrect or juggle them should be firmly struck down. The system of judicial review should not be misused and abused to evade the operation of final and executory judgments."
• "Moreover, the remand of a case does not nullify the entire proceedings. It merely authorizes the trial court to receive additional evidence, not to conduct a trial de novo."
• "It is axiomatic that once a decision attains finality, it becomes the law of the case regardless of any claim that it is erroneous."

• Ramos v. Court of Appeals, 275 SCRA 167 (1997) — Cited to support the rule that failure to attach a material portion of the record, such as the CA decision allegedly annulling the RTC decision, is sufficient ground for dismissal of the petition.
• Rubio v. MTCC, 252 SCRA 172 (1996); Soco v. Court of Appeals, 263 SCRA 449 (1996) — Cited for the proposition that once a judgment becomes final and executory, the issuance of a Writ of Execution becomes a ministerial duty of the court.
• Asuncion v. NLRC, 273 SCRA 498 (1997); Enriquez v. Court of Appeals, 202 SCRA 487 (1991) — Cited for the doctrine that a final decision becomes the law of the case regardless of any claim that it is erroneous.
• San Juan v. Cuento, 160 SCRA 277 (1988) — Cited for the principle that a judgment rendered by a court of competent jurisdiction may no longer be altered even at the risk of occasional legal infirmities or errors.
• Phil. National Bank v. Barretto, 52 Phil 818 (1929) — Cited as controlling precedent for the rule that an existing final judgment is conclusive of the rights of the parties and their privies in all other actions touching on the same points or matters in issue.

• Section 5, in relation to Section 4, Rule 45 of the 1997 Rules of Court — Governs appeals by certiorari to the Supreme Court. The Court applied this provision to emphasize that the failure of petitioner to attach a copy of the March 30, 1990 CA Decision, which he claimed annulled the RTC decision, was a material omission sufficient ground for the petition's dismissal, as it is a "material portion of the record [that] would support the petition."

Melo (Chairman), Vitug, Purisima, and Gonzaga-Reyes, JJ.