Yesterday's decision reinstated a lawsuit against Ganal by Wendy Touchette, who was severely burned in a fire at her Kailua home that killed her two children.
Her husband, Michael, also burned in the fire, later died in the hospital.
The crime spree also left Mabel Ganal's parents dead in a shooting at their Waipahu home that she and her son survived.
The rampage was touched off by Orlando Ganal Sr.'s anger over estranged wife Mabel's extramarital affair with Michael Touchette's brother David.
The Supreme Court said the Circuit Court failed to consider whether Mabel Ganal was partially responsible for the crimes because she taunted and humiliated Orlando Ganal with the affair, causing him to suffer extreme emotional and mental distress.
Touchette won a default judgment to collect $29 million from the convicted murderer in October 1994, but with little hope of collecting.
It appeared the only asset Ganal had was a Waipahu home, which was also in the name of wife Mabel.
The Supreme Court on May 8, 1996, upheld Orlando Ganal's 1993 life-without-parole sentence for murder and attempted murder.