CATILANO GUIADO ET AL., PLAINTIFFS AND APPELLANTS, VS. SALUSTIANO CULAO ET AL., DEFENDANTS AND APPELLANTS.

Catilano Guiado versus Culao

The Case

This is an action concerning land, brought by Catilano Guiado and others as plaintiffs against Salustiano Culao and others as defendants, and it comes to us on appeal from the Court of First Instance of Pampanga. The plaintiffs sued to establish their rights over the land in question and to recover it from the defendants, who held and claimed it as their own. The case matters to a reviewee for a narrower reason: it is a study in how the Supreme Court treats the findings of the trial court on appeal, and in what an appellant must show before this Court will disturb an order that was rendered after the parties submitted the cause for decision. The decision itself is brief, and its teaching lies less in elaborate doctrine than in the discipline of appellate review.

Procedural History

The action was commenced in the Court of First Instance of Pampanga, where the parties joined issue over the land and submitted the cause for decision. On the second of December, nineteen hundred and thirty-two, that court issued its order in the case. From that order the defendants appealed to the Supreme Court. The record shows that this Court regularly acquired jurisdiction over the appeal, that both parties submitted the cause for decision, and that after consideration of the record the Court rendered its decision and order for judgment on the fifth of May, nineteen hundred and thirty-four. The appeal was taken directly from the order of the Court of First Instance, and the Supreme Court resolved it on the record as submitted.

Facts

The plaintiffs, Catilano Guiado and others, asserted a right to the land that the defendants, Salustiano Culao and others, were holding. The defendants resisted the claim and maintained their own position over the property. The dispute was joined in the Court of First Instance of Pampanga, and the parties, rather than prolonging the proceedings, submitted the cause for decision upon the record.

On the second of December, nineteen hundred and thirty-two, the trial court issued the order that is the subject of the appeal. That order resolved the controversy in a manner adverse to the defendants, who thereupon appealed to the Supreme Court.

Before the Supreme Court the cause was again submitted for decision by both parties. The Court examined the record and, on the fifth of May, nineteen hundred and thirty-four, rendered its decision and order for judgment, affirming the order appealed from in all its parts.

Issues

• Whether or not the order of the Court of First Instance of Pampanga, dated the second of December, nineteen hundred and thirty-two, should be affirmed on appeal.
• Whether or not the appellants have shown any ground in the record sufficient to warrant a reversal or modification of that order.

Applicable Provisions

The decision does not quote or construe any statutory provision. It rests on the settled rule of appellate practice that an order of the Court of First Instance, regularly rendered after the cause is submitted for decision, is affirmed in all its parts where the record discloses no ground for reversal. No article of the Civil Code, the Code of Civil Procedure, or any other statute is set out in the text, and none is supplied here.

Ruling

On the first issue, the Court affirmed the order of the Court of First Instance of Pampanga in all its parts. The Court noted that it had regularly acquired jurisdiction over the cause, that the cause had been submitted by both parties for decision, and that upon consideration of the record its decision and order for judgment had been filed. The order appealed from was therefore left undisturbed.

On the second issue, the Court found nothing in the record that would justify setting aside the trial court's order. The appellants having submitted the cause for decision and having failed to show reversible error in the record, the appeal did not prosper. The affirmance was entered without special pronouncement as to the costs.

Doctrine

An order of the Court of First Instance rendered after both parties have submitted the cause for decision will be affirmed in all its parts on appeal where the record discloses no ground for reversal. The appellant bears the burden of demonstrating, from the record, that the court below erred; the Supreme Court does not disturb the order appealed from merely because the losing party is dissatisfied with it. Where the appeal presents no reversible error, the proper disposition is affirmance in all its parts, and costs are ordinarily left without special pronouncement.

Disposition

The Supreme Court affirmed the order of the Court of First Instance of Pampanga in all its parts, without special pronouncement as to the costs, and the defendants and appellants therefore lost their appeal.

Remember This

The line worth memorizing is that an order of the Court of First Instance, regularly rendered after the cause is submitted for decision, is affirmed in all its parts where the record shows no ground for reversal. Examiners use this case to test the burden of the appellant on appeal and the deference owed to the findings and orders of the trial court.