Binarao v. Plus Builders
REITERATIONFacts
The Antecedents: Spouses Jose and Preciosisima Binarao (petitioners) purchased a house and lot from Plus Builders, Inc. (respondent) for P327,491.95. Petitioner Jose Binarao executed an Affidavit of Undertaking to pay P96,791.95 as equity, with P5,000.00 upon signing and the balance within 15 days. Petitioners failed to fully comply with this undertaking. Procedural History: Respondent sent demand letters. On July 6, 1998, petitioners paid P20,000.00, leaving a balance of P65,571.22 payable in installments. Despite another demand letter on March 10, 1999, petitioners refused to pay. Respondent filed a complaint for a sum of money. The Metropolitan Trial Court (MTC) ruled in favor of respondent, ordering petitioners to pay the outstanding balance with interest, liquidated damages, and attorney's fees. The Regional Trial Court (RTC) affirmed the MTC decision. The Court of Appeals (CA) also affirmed the RTC decision, holding that petitioners admitted the material allegations in respondent's complaint, specifically the outstanding balance. The Petition: Petitioners filed a petition for review on certiorari, questioning whether they absolutely admitted their liability under the proposed payment plan dated July 6, 1998.
Issue(s)
Whether petitioners absolutely admitted their liability under the proposed payment plan dated July 6, 1998, and whether the admission in their Answer constitutes a judicial admission binding upon them.
Ruling
The petition is denied. The Decision of the Court of Appeals affirming the RTC Decision is affirmed in toto.
Ratio Decidendi
On Whether petitioners absolutely admitted their liability under the proposed payment plan dated July 6, 1998, and whether the admission in their Answer constitutes a judicial admission binding upon them: The Court held that petitioners made a judicial admission in their Answer to the complaint. Specifically, in paragraph 1 of their Answer, they admitted paragraphs 1 and 4 of the respondent's complaint. Paragraph 4 of the complaint stated three facts: (1) that petitioners paid P20,000.00 to respondent; (2) that petitioners still have a balance of P65,571.22; and (3) that such unpaid balance is to be paid in three agreed installments under a payment plan. While petitioners, in paragraph 7 of their Answer, qualified that they did not sign any payment plan, this qualification did not deny or negate the other admitted facts in paragraph 4, particularly the existence of an outstanding balance. The Court emphasized that the admission of the outstanding balance of P65,571.22 is conclusive against the petitioners. The Court reiterated the principle that a judicial admission, whether verbal or written, made by a party in the course of the proceedings in the same case, does not require proof and is conclusive against the party making it. This is provided for under Section 4, Rule 129 of the Revised Rules of Court. Such admissions can only be contradicted by showing that they were made through palpable mistake or that no such admission was made. In this case, petitioners failed to demonstrate any palpable mistake in their admission of the outstanding balance. Therefore, the admission in their pleadings is binding and conclusive, leaving no room for further dispute on the existence of the debt.
Main Doctrine
A judicial admission made in the pleadings is conclusive against the party making it, unless it is shown to have been made through palpable mistake. Such admission does not require further proof.