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	GR No. 194270 2012-12-03	LORETO BOTE v. SPS. ROBERT VELOSO AND GLORIA VELOSO VELASCO JR., J.
In Commissioner of Internal Revenue v. Mirant Pagbilao Corporation (formerly Southern Energy Quezon, Inc.),[31] the Court reiterated the thrust of the theory-of-the-case principle in this wise: It is already well-settled in this jurisdiction that a party may not change his theory of the case on appeal. Such a rule has been expressly adopted in Rule 44, Section 15 of the 1997 Rules of Civil Procedure, which provides