G.R. No. 118509 - Limketkai Sons Milling, Inc. vs. Court of Appeals

The petitioner, Limketkai Sons Milling, Inc., filed a motion for reconsideration of the Court’s resolution dated March 29, 1996, which itself set aside a prior decision rendered on December 1, 1995.
The motion challenged not only the merits of the evidentiary rulings but also the internal reorganization and composition of the Third Division of the Court.

The petitioner contended that certain doctrines established in previous cases—specifically Abrenica v. Gonda and De Gracia, Talosig v. Vda. de Nieba, and Villonco Realty Co. v. Bormaheco, Inc.—had been modified or reversed, urging a referral of the case to the Court En Banc.
It was argued that the direct testimonies, rendered in “affidavit form,” were admitted over the persistent objection of the counsels for the private respondents.
The petitioner emphasized that since the evidentiary material was presented in affidavit form, objections raised should have had greater remedial effect than allowed, as opposed to oral testimony where immediate objection is more readily administered.

A significant portion of the petitioner’s objection focused on the change in the composition of the Court’s divisions following the retirement of Justice Florentino P. Feliciano.
The petitioner questioned the appointment of Chief Justice Narvasa as the chairman of the Third Division, insisting that another configuration—assigning the First Division to Chief Justice Narvasa, the Second to the next senior Justice, and the Third to the third in line—had been more appropriate.
Historical precedent was cited, noting that a similar “staggered” arrangement in chairmanships existed as early as 1988, thus underlining the internal and administrative nature of the reorganization.
The petitioner also highlighted that motions for reconsideration by the private respondents had been timely and were integrated into the Court’s agenda in a routine manner, thereby casting the subsequent objections as untimely and prejudicial.

The petitioner accused the counsel for the private respondents of failing to properly secure objections against the admission of allegedly inadmissible evidence, specifically testimony that purportedly established a verbal contract of sale.
Detailed excerpts from trial proceedings were cited, including instances where counsels objected to the affidavit portions and the interpretation of the best evidence and parol evidence rules.
The petitioner alleged that a “double standard” was employed by the ponente, claiming inconsistency between his authoritative opinions in case reports and his handling of the evidence in the present matter.
In response, the Court underscored that the relevant objections were raised at the proper time during the presentation of the affidavit-form testimonies, and that such objections could not be retroactively applied given the procedural context.

Whether the reorganization and internal composition of the Court’s Third Division—particularly the appointment of Chief Justice Narvasa as chairman—affected the impartiality and fairness of the Court’s proceedings.
Whether the evidentiary rulings regarding the admission of affidavit-form testimonies, in light of objections concerning the parol evidence rule and the best evidence rule, were proper and in accordance with applicable procedural rules.
Whether the doctrines established in previous cases (Abrenica, Talosig, and Villonco) were wrongly or improperly applied in the instant case, or whether factual differences justified the Court’s approach in this instance.
Whether the petitioner’s motion for reconsideration and the alleged need to refer the case to the Court En Banc were justified based on errors or irregularities in the earlier decisions.