Case Digest (G.R. No. 226587)
Facts:
Donabelle V. Gonzales-Saldana v. Spouses Gordon R. Niamatali and Amy V. Niamatali, G.R. No. 226587, November 21, 2018, the Supreme Court Third Division, Reyes, Jr., J., writing for the Court.In January 2002 the respondent-spouses, then residing in the United States, told Donabelle Gonzales-Saldana (petitioner), who worked at the Department of Labor and Employment, that they wanted to acquire real property in Metro Manila and authorized petitioner to participate in a DOLE sheriff’s public auction of a Las Piñas parcel. On January 30, 2002 they remitted US$60,000 (P3,000,000) to petitioner’s bank account for that purchase. Petitioner later furnished photocopies of Transfer Certificates of Title for Manila and Parañaque properties and explained the Las Piñas auction failed because of a third-party claim; she said the judgment creditor offered other levied properties instead.
When the respondent-spouses returned to the Philippines in July 2002 they found the Las Piñas lot occupied and asked for return of their money; petitioner acknowledged receipt in a letter and promised to return the P3,000,000 by September 14, 2002. Petitioner averred she had asked a friend, Alninia Austria, to bid for the Manila and Parañaque properties and that Austria was the winning bidder; petitioner asserted she intended to sell those properties to reimburse the spouses.
After repeated demands and no refund, the respondent-spouses filed a complaint on March 6, 2006 for recovery of sum of money, moral damages and attorney’s fees (Civil Case No. 7720, RTC, Kalibo, Aklan). In a March 11, 2014 decision the Regional Trial Court dismissed the complaint: it excluded the uncertified photocopies of bank transfer records and the unsigned private acknowledgment/promissory note under the Best Evidence Rule, finding plaintiffs failed to prove their case.
The spouses appealed to the Court of Appeals (CA-G.R. CV No. 05172). In a March 31, 2016 decision the Court of Appeals reversed, treating petitioner’s statements in her Answer as a judicial admission that she received P3,000,000 and ruling she was bound to return it because the Las Piñas purchase did not materialize; the CA awarded P3,000,000 with 6% per annum interest from default until finality and th...(Pro-only)
Issues:
- Do the statements in petitioner’s Answer constitute judicial admissions binding on her?
- Is petitioner liable to return the P3,000,000 remitted by the respondent-spouses for the intended purchase of the Las Piñas property?
- Is petitioner liable to pay interest on the amount due, and if so, from wha...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)