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Judicial Admissions in Property Dispute

The Supreme Court ruled that a statement made in a complaint can be considered a judicial admission. Specifically, Programme Inc. acknowledged in its complaint that the original owner BASECO had leased Piazza Hotel to Programme, establishing that Programme did not own the property. As such, Programme's claim of ownership over the hotel was contradicted by its own admission. The Court also found that Programme did not provide any evidence that it had constructed or renovated the hotel at its own expense. Therefore, the petition was denied and the Court of Appeals' decision upholding the province of Bataan's ownership was affirmed.

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107 views2 pages

Judicial Admissions in Property Dispute

The Supreme Court ruled that a statement made in a complaint can be considered a judicial admission. Specifically, Programme Inc. acknowledged in its complaint that the original owner BASECO had leased Piazza Hotel to Programme, establishing that Programme did not own the property. As such, Programme's claim of ownership over the hotel was contradicted by its own admission. The Court also found that Programme did not provide any evidence that it had constructed or renovated the hotel at its own expense. Therefore, the petition was denied and the Court of Appeals' decision upholding the province of Bataan's ownership was affirmed.

Uploaded by

Tootsie Guzma
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd

Admissions of a party

Programme Inc. v. Province of Bataan, G.R. No. 144635, June 26, 2006; -Panelo

DOCTRINE:
An admission, verbal, or written, made by a party in the course of the proceedings in the
same case, does not require proof; To be considered as a judicial admission, the same
must be made in the same case in which it is offered.

· Such admissions may be made in (a) the pleadings filed by the parties, (b) in the
course of the trial either by verbal or written manifestations or stipulations, or (c)
in other stages of the judicial proceeding, as in the pre-trial of the case

FACTS:
Programme Inc. assailed CA’s decision affirming the RTC’s decision upholding the
respondent Province of Bataan’s ownership of Piazza Hotel and the land on which it
stands.

BASECO was the original owner of Piazza Hotel and Mariveles Lodge in Mariveles,
Bataan. On May 1986, Programme Inc. leased the Piazza Hotel for 3 years (until Jan. 1,
1989). After the period, Programme was allowed to continue operating the hotel on
monthly extensions of the lease.

On April 1989, PCGG issued a sequestration order against BASECO, pursuant to EO 1.


Among the properties seize was the lot on which Piazza Hotel stood. Afterwards, Piazza
Hotel was sold at a public auction for non-payment of taxes to respondent Bataan. The
title was transferred to Province of Bataan. Program claimed ownership of said property.
However, in the complaint for preliminary injunction, it acknowledged that
BASECO leased to Programme the building.

Bataan as the new owner filed a motion to intervene. The motion of Bataan was
granted, and thus it filed a complaint praying that Programmed to vacate Piazza Hotel
and Mariels Lodge.

The issue on the ownership of Bataan was heard before the trial court which the RTC
ruled in favor of Bataan

CA: AFFIRMED,
· Bataan has established by preponderance of evidence its claim of ownership.
· In fact, Programme has not presented evidence proving its ownership over the
buildings, whereas Bataan presented a tax declaration and Certificate of TUtle
over the same properties

ISSUE: WON the statement in the complaint is considered a judicial admission


RULING:

Yes, it is a judicial admission. Such admissions may be made in (a) the pleading
filed by the parties, (b) in the course of trial either by verbal or written
manifestations or stipulations, or (c) in other stages of the judicial proceedings,
as in the pre-trial of the case. Admissions obtained through depositions, written
interrogatories or requests for admission are also considered judicial admissions.
Petitioner could not possibly be the owner of a building merely leased to it.

In Programme’s complaint for preliminary injunction and sum of money, it


acknowledged that it was not the owner of the property when it stated that
BASECO leased to Programme Inc. the Piazza Hotel for P6.5k/month

PIAZZA HOTEL WAS NOT CONSTUCTED AT PROGRAMME’S EXPENSE.

No evidence was submitted to support such claim. Neither did any document or
testimony prove this claim. What was proven was that Programme had only
managed and operated the hotel. Therefore, Programme cannot seek
reimbursement for the expense on construction/renovation.

Disposition: petition Denied. CA Decision Affirmed.

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