Case Digest (G.R. No. 226587)
Facts:
In Donabelle V. Gonzales-Saldana vs. Spouses Gordon R. Niamatali and Amy V. Niamatali (G.R. No. 226587, November 21, 2018), the spouses Niamatali, then in the United States, requested petitioner Gonzales-Saldana, a DOLE employee, to bid for a Las Piñas parcel at a DOLE Sheriff’s public auction. On January 30, 2002, they remitted US$60,000 (₱3,000,000) to her bank account. When the Las Piñas sale failed due to a third-party claim, petitioner purportedly purchased Manila and Parañaque properties instead, without their express consent, and sent them photocopies of Transfer Certificates of Title Nos. 105904 and 223102. Upon returning in July 2002 and finding the Las Piñas property locked with a school signboard, the spouses demanded their money back. Petitioner acknowledged receipt and promised repayment by September 14, 2002, but failed to do so despite repeated demands. On March 6, 2006, the Niamatalis filed a complaint for recovery of sum of money with damages and attorney’s feesCase Digest (G.R. No. 226587)
Facts:
- Background and Agreement
- In January 2002, spouses Gordon and Amy Niamatali, then residing in the United States, instructed petitioner Donabelle Gonzales-Saldana (a DOLE employee) to bid in a DOLE Sheriff’s Office public auction for a parcel in Las Piñas City.
- The spouses remitted US$60,000 (₱3,000,000) to petitioner’s bank account for that purpose.
- Substitution of Property and Demand for Refund
- In March 2002, petitioner sent the spouses photocopies of TCT Nos. 105904 and 223102 (Manila and Parañaque properties), explaining that the Las Piñas sale failed due to a third-party claim and that the judgment creditor offered the other properties instead. The spouses did not consent to this substitution.
- Upon their July 2002 return to the Philippines, the spouses found the Las Piñas property locked and labeled for a school project. They demanded the ₱3,000,000 refund. Petitioner acknowledged receipt and promised to return the amount by September 14, 2002, but failed to do so.
- Judicial Proceedings
- March 6, 2006: Spouses filed a complaint in RTC Kalibo for collection of sum of money (₱3,000,000), moral damages, and attorney’s fees (Civil Case No. 7720).
- March 11, 2014: The RTC dismissed the complaint for failure to comply with the Best Evidence Rule (photocopied bank documents and unnotarized promissory note inadmissible).
- March 31, 2016: The CA reversed, treating petitioner’s admission of receipt in her Answer as a judicial admission, ordered payment of ₱3,000,000 plus 6% interest per annum from default until full satisfaction.
- August 10, 2016: CA denied petitioner’s motion for reconsideration.
- November 21, 2018: Petitioner filed a petition for review on certiorari before the Supreme Court raising errors on judicial admission, admissibility of evidence, unjust enrichment, and interest.
Issues:
- Are petitioner’s statements in her Answer judicial admissions?
- Is petitioner obligated to return the ₱3,000,000 she received for the Las Piñas property?
- Is petitioner liable for interest on the ₱3,000,000, and if so, at what rate and from what date?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)