Stare decisis applies only to Supreme Court-decided cases

In the case of UCPB v. Spouses Uy (G.R. No. 204039, January 10, 2018), respondents bewailed the reliance of the Court of Appeals (CA) on the case of UCPB v. O'Halloran, which is a CA-decided case, arguing that it was not a binding precedent since it was not issued by the Supreme Court. In De Mesa v. Pepsi-Cola Products,[1] the High Court explained that the doctrine of stare decisis deems decisions of the Philippine Supreme Court binding on the lower courts, to wit:
The principle of stare decisis et non quieta movere is entrenched in Article 8 of the Civil Code, to wit: "Judicial decisions applying or interpreting the laws or the Constitution shall form a part of the legal system of the Philippines." xxx

It enjoins adherence to judicial precedents. It requires our courts to follow a rule already established in a final decision of the Supreme CourtThat decision becomes a judicial precedent to be followed in subsequent cases by all courts in the land. The doctrine of stare decisis is based on the principle that once a question of law has been examined and decided, it should be deemed settled and closed to further argument.
In other words, the doctrine of stare decisis becomes operative only when judicial precedents are set by pronouncements of the Highest Court of the Land, the Supreme Court, to the exclusion of lower courts. It is true regardless whether the decisions of the lower courts are logically or legally sound as only decisions issued by the Supreme Court become part of the legal system.

At the most, decisions of lower courts, especially those of the CA, only have a persuasive effect. Thus, respondents in UCPB v. Spouses Uy are correct in contesting the application of the doctrine of stare decisis when the CA relied on decisions it had issued.

[1] 504 Phil. 685 (2005).

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