Title
Gonzales-Saldana vs. Spouses Niamatali
Case
G.R. No. 226587
Decision Date
Nov 21, 2018
Petitioner entrusted with P3M to buy property, breached agreement by purchasing others, failed to return funds; ordered to repay with interest.
dispute
obligation
purchase

Case Summary (G.R. No. 226587)

Factual Background

In January 2002, while residing in the United States, the Spouses Gordon R. Niamatali and Amy V. Niamatali communicated to Donabelle V. Gonzales-Saldana their intention to acquire real property in Metro Manila. Petitioner informed them of a DOLE sheriff auction for a parcel in Las Piñas. On January 30, 2002, the spouses remitted US$60,000.00 or P3,000,000.00 to petitioner’s bank account for that purchase. In March 2002 petitioner furnished photocopies of Transfer Certificates of Title for properties in Manila and Parañaque and explained that the Las Piñas auction did not push through because of a third-party claim; petitioner said the judgment creditor offered the Manila and Parañaque properties instead. On their return in July 2002, the spouses found the Las Piñas property locked with a signboard. The spouses declared they no longer wanted Las Piñas and demanded return of P3,000,000.00; petitioner acknowledged receipt and promised to return the money on or before September 14, 2002, but did not do so.

Trial Court Proceedings and Ruling

The Spouses filed a complaint for collection of sum of money, moral damages, and attorney's fees on March 6, 2006. The Regional Trial Court evaluated documentary evidence and excluded uncertified photocopies of the bank transfer under the Best Evidence Rule because plaintiffs failed to prove loss of the originals. The trial court also deemed inadmissible the alleged acknowledgment receipt or promissory note for lack of notarization and absence of witnesses to prove petitioner’s signature. Finding plaintiffs failed to present a preponderance of evidence, the RTC rendered judgment dismissing the complaint and counterclaim in its March 11, 2014 Decision.

Court of Appeals Decision

On appeal, the Court of Appeals treated petitioner’s admission in her Answer regarding receipt of P3,000,000.00 as a judicial admission and held that such admission dispensed with the need for proof of remittance. The CA concluded petitioner was bound to return the P3,000,000.00 because the Las Piñas purchase did not materialize. The CA reversed and set aside the RTC decision and ordered petitioner to pay P3,000,000.00 with interest at six percent per annum from default until finality and thereafter until full satisfaction. Petitioner’s motion for reconsideration was denied in an August 10, 2016 Resolution.

Issues Presented on Review

The petition to the Supreme Court raised five principal assignments of error which the Court distilled into three controlling issues: whether statements in petitioner’s Answer constituted judicial admissions binding on petitioner; whether petitioner was obliged to return the P3,000,000.00 remitted by the spouses for the Las Piñas purchase; and whether petitioner was liable for interest on the amount due and, if so, the appropriate rate and commencement date.

Parties' Contentions

Petitioner argued that her Answer contained defenses demonstrating lack of cause of action rather than admissions; that the supposed admission referred to a different factual context involving borrowed money; that any obligation to return the funds was contingent upon sale of the substitute Manila and Parañaque properties; that the doctrine of unjust enrichment did not apply; and that no interest was due because there was no written loan agreement and no stipulation for interest. The Spouses countered that petitioner failed to inform them of the property status since 2002, that recovery of money is proper notwithstanding the contract label, and that legal interest should be imposed because petitioner was in delay.

Judicial Admission — Supreme Court Analysis

The Supreme Court held that the statements in petitioner’s Answer constituted judicial admissions and therefore bound petitioner. The Court explained that a judicial admission is an admission made in the course of the proceedings which dispenses with the need for proof and may be contradicted only by proof of palpable mistake or absence of such admission. The Court reviewed petitioner’s Answer and emphasized passages in which petitioner conceded that plaintiffs “may have sent money to defendant” and acknowledged use of the money to purchase properties, while denying only that she had coerced the remittance. The Court found that petitioner never denied receipt of P3,000,000.00 and failed to show palpable mistake; consequently her pleading admissions removed the fact of receipt from controversy and dispensed with the need to admit the bank documents excluded by the RTC.

Agency and Scope of Authority — Supreme Court Analysis

The Court found an implied agency relationship between petitioner and the Spouses for the purpose of acquiring the Las Piñas property. The Court traced the elements supporting implied agency: the spouses communicated their intent to purchase, remitted funds to petitioner’s account, and petitioner made inquiries with the DOLE sheriff and engaged the judgment creditor in furtherance of the transaction. The Court concluded petitioner acted beyond the scope of the authority granted when she procured and purchased the Manila and Parañaque properties without prior approval. Because petitioner breached her principal obligation to buy the Las Piñas property and substituted other purchases without consent, the spouses were entitled to the return of P3,000,000.00.

Award of Interest — Supreme Court Analysis

The Supreme Court distinguished monetary interest from c

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