Silot v. De la Rosa
REITERATIONFacts
The Antecedents: Petitioner Gregorio Silot, Jr. and respondent Estrella de la Rosa entered into a contract for the construction of a dormitory-apartment building. Silot was to supply labor, and de la Rosa was to pay 33% of the total value of materials purchased. Upon completion, de la Rosa paid P1,018,000.00, which Silot claimed was P191,525.02 less than the agreed 33% of the P2,504,469.65 material cost. De la Rosa, however, contended that Silot had been overpaid by P191,525.02 and demanded a refund, which Silot refused. Silot subsequently sued de la Rosa for alleged insufficient payment, claiming a balance of P273,872.40. Procedural History: The two consolidated cases were heard by the Regional Trial Court (RTC), Branch 61, Naga City. During the proceedings, Silot's counsel, Atty. San Jose, admitted the proposed testimony of de la Rosa's witness, Ariel Goingo. This testimony, if admitted, would establish that all material supplies for the project, including additional works, were accounted for, that Silot was paid for all performed works and supplied materials, that the total material cost was P2,504,469.65, making 33% of it P826,474.98, that de la Rosa paid P1,018,000.00 resulting in an overpayment of P191,525.02, and that de la Rosa never received any demand for an alleged balance. Consequently, the RTC ruled in favor of de la Rosa, ordering Silot to return the overpaid amount of P191,525.02, along with attorney's fees and nominal damages. The Court of Appeals affirmed the RTC decision with modification, deleting the award for nominal damages and reducing attorney's fees. The Petition: Petitioner Gregorio Silot, Jr. filed a petition for review with the Supreme Court, raising two main issues. First, he argued that his counsel's admission regarding Ariel Goingo's testimony should not be considered a judicial admission of evidence, as it was merely an admission of the purpose of the testimony and not its truthfulness, and that his counsel lacked the authority to make such admissions without his direct intervention. Second, he challenged the appellate court's decision ordering him to return P191,525.02 to de la Rosa. The Supreme Court considered whether the admission made by Silot's counsel constituted a binding judicial admission and whether the appellate court erred in its ruling on the overpayment.
Issue(s)
Whether the admission made by petitioner's counsel constituted a judicial admission of respondent's evidence. Whether the appellate court erred in ordering petitioner to return the claimed amount of P191,525.02 to respondent and to pay attorney's fees.
Ruling
The Supreme Court denied the petition for lack of merit. It affirmed the decision of the Court of Appeals, ordering petitioner Gregorio Silot, Jr. to return the amount of P191,525.02 to respondent Estrella de la Rosa and to pay P20,000.00 as attorney's fees.
Ratio Decidendi
On the issue of judicial admission: The Court held that the admission made by petitioner's counsel, Atty. San Jose, constituted a judicial admission. The records showed that Atty. San Jose repeatedly agreed to admit the purpose of Ariel Goingo's testimony, which was to establish the overpayment and the lack of demand for an alleged balance. Such admissions, made to dispense with the presentation of evidence, are binding upon the client. The Court reiterated the principle that clients are bound by the admissions of their counsel, citing several cases, and that this rule admits of exceptions only in cases of palpable mistake or gross negligence that deprives the client of their day in court, which were not present here. The Court emphasized that Silot was not deprived of his day in court and had the opportunity to present evidence or correct the admission. On the issue of overpayment and attorney's fees: Based on the judicial admission made by his counsel, the Court found that Silot was indeed paid more than what was due to him under the contract. The admission confirmed that de la Rosa paid P1,018,000.00, while 33% of the material costs, which was Silot's share, amounted to P826,474.98, resulting in an overpayment of P191,525.02. The Court also noted that the admission explicitly stated that de la Rosa never received any demand from Silot regarding an alleged balance. Therefore, the appellate court did not err in ordering Silot to return the overpaid amount. The award of attorney's fees was affirmed as modified by the CA, considering the necessity of litigation to enforce de la Rosa's right to recover the overpayment.
Main Doctrine
A client is bound by the admissions made by their counsel during trial, especially when such admissions are made to dispense with the presentation of evidence, unless there is a showing of palpable mistake or gross negligence that deprives the client of their day in court. Such admissions are considered judicial admissions and are conclusive upon the parties.