G.R. No. L-56385 May 19, 1984
RENATO U. REYES, petitioner, vs. THE COMMISSION ON ELECTIONS AND ERNESTO LIWANAG, respondents.

FACTS

This case originates from a prior Supreme Court decision in G.R. No. 52699 (Reyes v. COMELEC). In that case, petitioner Renato U. Reyes was a mayoral candidate in Bongabon, Oriental Mindoro. The COMELEC disqualified him via a resolution dated February 7, 1980, after the election was held on January 30, 1980, where he obtained more votes. The Supreme Court nullified the COMELEC resolution and the subsequent proclamation of his opponent, Jose A. Enriquez, for lack of procedural due process, as Reyes was not heard on his disqualification. The Court ordered Reyes’s proclamation and, crucially, referred the disqualification question back to COMELEC for a proper hearing.
Pursuant to that remand, COMELEC set the disqualification case for hearing. Reyes filed a motion to dismiss, arguing COMELEC lost jurisdiction because he had already been proclaimed and an election protest (filed by Enriquez in March 1980) was pending in the Court of First Instance, raising the same issue of disqualification. COMELEC denied his motion, citing the explicit directive from the Supreme Court to hear the disqualification case. Reyes then filed this present petition to stop COMELEC from proceeding.

ISSUE

Whether the COMELEC can be prohibited from conducting a hearing on the disqualification case against petitioner, which was specifically remanded to it by the Supreme Court in a final and executory decision.

RULING

The Supreme Court DISMISSED the petition, upholding COMELEC’s authority to proceed with the hearing. The ruling is anchored on the doctrine of the “law of the case.” The prior decision in G.R. No. 52699 , which ordered the case remanded to COMELEC for a hearing on disqualification, constitutes the controlling legal rule for this controversy between the same parties. This doctrine means that a point of law expressly or impliedly settled by a court in a former appeal of the same case continues to govern throughout its subsequent stages, irrespective of its correctness, so long as the facts remain substantially the same.
The Court rejected petitioner’s reliance on the doctrine from Arcenas v. COMELEC, which holds that pre-proclamation controversies become non-viable after proclamation. The Arcenas doctrine applies to new cases, not to a situation like this where the Supreme Court itself, in a final decision, specifically mandated a post-proclamation proceeding. Petitioner cannot seek relief from this Court and then, after obtaining a favorable ruling that included a remand, file a new action to prevent the execution of that very ruling. The pending election protest does not divest COMELEC of jurisdiction to complete the task assigned to it by the Court’s final judgment. The principle of finality of judgments and orderly judicial process demands compliance with the remand order.