Issues that may be raised on appeal

In the case of UCPB v. Spouses Uy (G.R. No. 204039, January 10, 2018), respondents alleged that the Court of Appeals (CA) erred in applying "United Coconut Planters Bank v. O'Halloran," a CA-decided case, because the circumstances were different, notably the issue that estoppel did not arise in the said case. In addition, they argued that O'Halloran and the other cases cited by UCPB are not binding pursuant to the doctrine of stare decisis because they were decided by the CA and not by this Court. As such, respondents posited that only decisions of the Supreme Court, excluding all other courts such as the CA, form part of the legal system.

On the other hand, UCPB countered that the only issue to be resolved in the petition is the actual amount of its liability. It explained that the assailed CA decision had become final and executory after respondents failed to appeal the same. UCPB pointed out that the issues respondents raised were already ventilated before the appellate court. It believed that respondents should have filed their own appeal to assail the issues they found questionable.It must be remembered that when a case is appealed, the appellate court has the power to review the case in its entirety.[1] In Heirs of Alcaraz v. Republic,[2] the Supreme Court explained that an appellate court is empowered to make its own judgment as it deems to be a just determination of the case, to wit:

In any event, when petitioners interposed an appeal to the Court of Appeals, the appealed case was thereby thrown wide open for review by that court, which is thus necessarily empowered to come out with a judgment as it thinks would be a just determination of the controversy. Given this power, the appellate court has the authority to either affirm, reverse or modify the appealed decision of the trial court. To withhold from the appellate court its power to render an entirely new decision would violate its power of review and would, in effect, render it incapable of correcting patent errors committed by the lower courts.[2]

Thus, when UCPB appealed the present controversy before the Court, it was not merely limited to determine whether the CA accurately set UCPB's liability against respondents. It is also empowered to determine whether the appellate court's determination of liability was correct in the first place. This is especially true considering that the issue of the nature of UCPB's liability is closely intertwined and inseparable from the determination of the amount of its actual liability.

[1] Sazon v. Vasquez-Menancio, 682 Phil. 669, 679 (2012).

[2] 502 Phil. 521 (2005).