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### Facts:
1. **Complaint Filed:**
– On July 31, 1985, Stronghold Insurance Company, Inc. filed a complaint against Paquito B. Buaya, a former branch manager in Cebu, for unremitted premium collections amounting to PHP 678,076.83.
2. **Default Judgment:**
– Buaya and his counsel failed to appear at the scheduled pre-trial, resulting in Buaya being declared in default. The trial court rendered a decision (September 17, 1987) favoring Stronghold Insurance and ordered Buaya to pay PHP 678,076.83 plus interest and attorney’s fees.
3. **Appeal to Court of Appeals:**
– Buaya appealed the trial court’s decision to the Court of Appeals (CA-GR No. 17329). On March 30, 1990, the CA set aside the trial court’s decision and remanded the case for further proceedings.
4. **Series of Postponements:**
– Following the remand, multiple hearing postponements were requested by Buaya citing various reasons, including his counsel’s death and his own illness. The court granted several postponements but eventually, on December 19, 1991, denied further postponements and declared Buaya had waived his right to present evidence.
5. **Reinstatement of Decision:**
– Stronghold moved to reinstate the September 17, 1987 decision. Buaya’s motion for reconsideration was denied, and the trial court reinstated its original decision on March 18, 1992.
6. **Petition for Certiorari:**
– Buaya filed a petition for certiorari to the CA, which was dismissed on August 24, 1992. The Supreme Court dismissed a subsequent petition.
7. **Execution and Relief Petition:**
– An order for a writ of execution was issued on October 29, 1993. Buaya filed a motion for reconsideration and subsequently a petition for relief from the order, both of which were denied.
8. **Final Appeal to CA:**
– Buaya appealed the denial of his petition for relief, which was dismissed by the CA on August 28, 1998.
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### Issues:
1. Can a trial court reinstate a decision that was annulled by the Court of Appeals?
2. Does the remand of a case require a full retrial or merely the presentation of additional evidence by the plaintiff?
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### Court’s Decision:
1. **Annulled Decision:**
– The Supreme Court clarified that the CA did not annul but merely set aside the trial court’s decision, allowing Buaya the opportunity to present his evidence. Therefore, the trial court’s reinstatement of its earlier decision after Buaya failed to present his evidence was lawful and proper.
2. **Final and Executory Judgment:**
– The SC ruled that the trial court’s decision became final and executory on June 28, 1993. The issuance of the writ of execution followed standard procedures as Buaya failed to present any substantial evidence or argument that merited further reconsideration.
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### Doctrine:
– **Finality of Judgments:** Once a judgment becomes final and executory, it becomes the law of the case regardless of any claims of error. Courts are obligated to execute such judgments without delay.
– **Reinstatement of Decisions:** A decision that is set aside for further proceedings can be reinstated if the conditions leading to its setting aside are not adequately addressed by the affected party.
– **Judicial Review’s Limitation:** The system of judicial review should not be misused to evade final judgments.
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### Class Notes:
– **Key Concepts:**
– **Default Judgment:** Issued when a party fails to appear or respond.
– **Final and Executory:** A status where a judgment cannot be altered.
– **Remand and Reinstatement:** Remand for further proceedings does not nullify previous decisions unless explicitly annulled. Non-compliance can lead to reinstatement.
– **Certiorari:** A writ by which a higher court reviews a decision of a lower court.
– **Statutory Provisions:**
– **Rule 37 of the Rules of Court:** Pertains to post-judgment remedies such as motions for new trial or reconsideration.
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### Historical Background:
The case underlines the Philippine judiciary’s efforts to ensure finality in litigation and prevent procedural abuses or unnecessary delays. It exemplifies the balance courts must maintain between granting fair opportunities to litigants and upholding the integrity and finality of judicial decisions. This case rests within a broader historical context where the judiciary emphasizes efficient resolution mechanisms, reflecting a consistent judicial philosophy towards consolidating final judgments and curbing dilatory practices.
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