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EASTERN SHIPPING LINES, INC.

, Petitioner, vs. BPI/MS INSURANCE SPOUSES ALEJANDRO MANZANILLA AND REMEDIOS


CORP., & MITSUI SUMITOMO INSURANCE CO., LTD., Respondents. G.R. VELASCO, Petitioners, vs. WATERFIELDS INDUSTRIES CORPORATION,
No. 182864, January 12, 2015 PEREZ, J.: represented by its President, ALIZA MA, Respondent. G.R. No.177484,
July 18, 2014
TOPIC: Evidence; Judicial admission (Rule 129, Sec.4) DEL CASTILLO, J.:

DOCTRINE: Judicial admissions are legally binding on the party making the TOPIC: Evidence; Judicial Admission (Rule 129, Sec.4)
admissions and requires no proof.
DOCTRINE: It is well-settled that judicial admissions cannot be contradicted
FACTS: A Petition for Review on Certiorari of the Decision of the Second by the admitter who is the party [itself] and binds the person who makes the
Division of the Court of Appeals. A complaint for actual damages amounting same, and absent any showing that this was made thru palpable mistake (as
to US$17,560.48 was filed by herein respondents against Eastern Shipping in this case), no amount of rationalization can offset it.
Lines, Inc., (ESLI) covering steel subject to its shipment. Petitioner insisted
that it was through the management of the stevedore, Asian Terminals, Inc. FACTS: The spouses Manzanilla are the owners of a 25,000-square meter
(ATI) where the damages have been incurred. For failure to reach settlement parcel of land in Barangay San Miguel, Sto. Tomas, Batangas. On May 24,
on the legal issues it was submitted to trial and during the pre-trial several 1994, they leased a 6,000-square meter portion to Waterfields. The parties
stipulations of facts were admitted. The trial court ruled in favor of the executed on June 6, 1994 an Amendment to the Contract of Lease.
respondents. ESLI appealed disputing its liability as to the damaged goods Beginning April 1997, however, Waterfields failed to pay the monthly rental.
and invoking further the validity of the contents of the bill of lading. Hence, Waterfields President Ma sent the spouses Manzanilla a letter
promising to pay the unpaid rentals, due to lessees failure to comply with
ISSUE: Whether or not admissions made during the pre-trial as to the their obligation, spouses Manzanilla filed before the MTC a Complaint for
validity of the bills of lading are binding. Ejectment against Waterfields. MTC declared that Waterfields violated the
lease agreement due to non-payment of rentals. The case was elevated to the
RULING: YES. Judicial admissions are legally binding on the party making RTC where the latter affirmed the decision made by the MTC, however the CA
the admissions. Pre-trial admission in civil cases is one of the instances of reversed the decision that the contract of lease was already terminated
judicial admissions explicitly provided for under Section 7, Rule 18 of the because of the stipulation contained in their amended contract of lease which
Rules of Court, which mandates that the contents of the pre-trial order shall provides; The deposit stipulated in our lease contract shall be used
control the subsequent course of the action, thereby, defining and limiting exclusively for the payment of unpaid utilities, if any, and other incidental
the issues to be tried. In Bayas v. Sandiganbayan, this Court emphasized expenses only and applied at the termination of the lease, hence this petition
that: Once the stipulations are reduced into writing and signed by the parties for review on certiorari.
and their counsels, they become binding on the parties who made them.
They become judicial admissions of the fact or facts stipulated. Even if placed ISSUE: Whether or not Waterfields is correct in assailing the lack of cause of
at a disadvantageous position, a party may not be allowed to rescind them action by the petitioner.
unilaterally, it must assume the consequences of the disadvantage.
Moreover, in Alfelor v. Halasan, this Court declared that: A party who RULING: NO. Waterfields cannot contradict its judicial admission that the
judicially admits a fact cannot later challenge that fact as judicial admissions Contract of Lease was amended on July 9, 1997; the doctrine of estoppel
are a waiver of proof; production of evidence is dispensed with. A judicial likewise bars it from falsifying Ma’s July 9, 1997 letter in this litigation.
admission also removes an admitted fact from the field of controversy. Section 4, Rule 129 of the Rules of Court provides: SEC. 4. Judicial
Consequently, an admission made in the pleadings cannot be controverted admissions. – An admission, verbal or written, made by a party in the course
by the party making such admission and are conclusive as to such party, of the proceedings in the same case, does not require proof. The admission
and all proofs to the contrary or inconsistent therewith should be ignored, may be contradicted only by showing that it was made through palpable
whether objection is interposed by the party or not. The allegations, mistake or that no such admission was made. "A party may make judicial
statements or admissions contained in a pleading are conclusive as against admissions in (a) the pleadings, (b) during trial, either by verbal or written
the pleader. A party cannot subsequently take a position contrary of or manifestations or stipulations, or (c) in other stages of the judicial
inconsistent with what was pleaded. The admission having been made in a proceeding." Clearly, Waterfields admitted in its Answer the truth of the
stipulation of facts at pre-trial by the parties, it must be treated as a judicial material allegation that the Contract of Lease was amended on July 9, 1997.
admission. Under Section 4, of Rule 129 of the Rules of Court, a judicial Under the doctrine of estoppel, an admission or representation is rendered
admission requires no proof. conclusive upon the person making it, and cannot be denied or disproved as
against the person relying thereon. A party may not go back on his own acts
and representations to the prejudice of the other party who relied upon them.
In the law of evidence, whenever a party has, by his own declaration, act, or
omission, intentionally and deliberately led another to believe a particular RULING: NO. Petitioner was well aware that LHUILLIER had never admitted
thing [to be] true, and to act upon such belief, he cannot, in any litigation personal liability for the said obligation. as correctly observed by respondent
arising out of such declaration, act, or omission, be permitted to falsify it. court, if petitioner really believed that the liability was incurred by
LHUILLIER in his personal capacity, then he should not have offset his
FLORENTINO ATILLO III, Petitioner, v. COURT OF APPEALS, AMANCOR, accounts with those of AMANCOR’s. The foregoing act of petitioner is a clear
INC., and MICHELL LHUILLIER, Respondents. indication that he recognized AMANCOR and not LHUILLIER as the obligor.
G.R. No. 119053. January 23, 1997 FRANCISCO, J.: Granting arguendo that LHUILLIER had in fact made the alleged admission
of personal liability in his Answer, We hold that such admission is not
TOPIC: Evidence; Judicial admission; Exception to the conclusiveness of a conclusive upon him. Applicable by analogy is our ruling in the case of
judicial admission. Gardner v. Court of Appeals which allowed a party’s testimony in open court
to override admissions he made in his answer. Thus: "The fact, however, that
DOCTRINES: the allegations made by Ariosto Santos in his pleadings and in his
 As provided for in Section 4 of Rule 129 of the Rules of Court, the general declarations in open court differed will not militate against the findings
rule that a judicial admission is conclusive upon the party making it and herein made nor support the reversal by respondent court. As a general rule,
does not require proof admits of two exceptions: facts alleged in a party’s pleading are deemed admissions of that party and
1) When it is shown that the admission was made through are binding upon it, but this is not an absolute and inflexible rule. An answer
palpable mistake, and is a mere statement of fact which the party filing it expects to prove, but it is
2) When it is shown that no such admission was in fact made. not evidence. As ARIOSTO SANTOS himself, in open court, had repudiated
the defenses he had raised in his ANSWER and against his own interest, his
 It is clear that in spite of the presence of judicial admissions in a party’s testimony is deserving of weight and credence. Both the Trial Court and the
pleading, the trial court is still given leeway to consider other evidence Appellate Court believed in his credibility and we find no reason to overturn
presented. This rule should apply with more reason when the parties had their factual findings thereon." it is clear that in spite of the presence of
agreed to submit an issue for resolution of the trial court on the basis of judicial admissions in a party’s pleading, the trial court is still given leeway
the evidence presented. to consider other evidence presented. This rule should apply with more
reason when the parties had agreed to submit an issue for resolution of the
FACTS: Respondent AMANCOR a corporation then owned and controlled by trial court on the basis of the evidence presented.
petitioner Florentino L. Atillo III, contracted a loan with Metropolitan Bank
and Trust Company, secured by real estate properties owned by the
petitioner. Before the said loan could be paid, petitioner entered into a
Memorandum of Agreement with respondent LHUILLIER whereby the latter
bought shares of stock in AMANCOR. As a consequence of the foregoing
transaction, petitioner and LHUILLIER each became owner of 47% of the
outstanding shares of stock of AMANCOR while the officers of the corporation
owned the remaining 6%. In view of the urgent and immediate need for fresh
capital to support the business operations of AMANCOR, petitioner and
LHUILLIER executed another Memorandum of by virtue of which LHUILLIER
undertook to invest additional capital in AMANCOR. Thereafter, a
Supplemental Memorandum of Agreement was entered into by the petitioner
and LHUILLIER. Pursuant to supplemental memorandum, petitioner
assumed AMANCOR’ s outstanding loan balance of P300,000.00 with
Metropolitan Bank and Trust Company. After offsetting the amount of
P300,000.00 with some of the accounts that petitioner had with AMANCOR,
the amount which remained due to the petitioner was P199,888.89. Because
of the failure of AMANCOR to satisfy its obligation to repay petitioner, the
latter filed a complaint for collection of a sum of money against AMANCOR
and LHUILLIER.

ISSUE: Whether or not LHUILLIER is personally liable for the obligation of


AMANCOR to petitioner on the basis of judicial admission.

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