G.R. No. 126802. January 28, 2000.
ROBERTO G. ALARCON, petitioner, vs. THE COURT OF APPEALS and BIENVENIDO JUANI, respondents.

FACTS

Petitioner Roberto Alarcon filed a complaint for annulment of a deed of sale against respondents Bienvenido Juani, Edgardo Sulit, and Virginia Baluyot. Alarcon alleged that before working abroad, he left a Special Power of Attorney (SPA) with his father, Tomas Alarcon, to administer his property. Upon his return, he discovered that a 2,500-square-meter portion of his land was sold to the respondents based on a “Kasulatan ng Bilihang Tuluyan ng Bahagi ng Lupa” purportedly executed by Tomas in 1985. Alarcon contended the signature was forged, there was no consideration, and the SPA had been revoked earlier. New titles were issued in the respondents’ names.
During pre-trial conferences, the parties and their counsel made judicial admissions. They admitted that the deed of sale was a forged document, which was the subject of a pending criminal case, and that this forged document was registered, leading to the issuance of the respondents’ transfer certificates of title (TCTs). Based solely on these admissions, the trial court rendered a Partial Decision declaring the deed void ab initio and ordering the cancellation of the derived TCTs.

ISSUE

Whether the Court of Appeals erred in setting aside the trial court’s Partial Decision which was based on judicial admissions made during pre-trial.

RULING

The Supreme Court reversed the Court of Appeals and reinstated the trial court’s Partial Decision. The legal logic is anchored on the binding nature of judicial admissions made during pre-trial. Admissions made for the purpose of dispensing with proof at trial are conclusive upon the parties and cannot be contradicted unless shown to have been made through palpable mistake. The rules on pre-trial are designed to expedite proceedings, and stipulations or admissions of facts are mandatory components. Here, the respondents, through their counsel, explicitly and unequivocally admitted during the pre-trial that the deed of sale was forged. This admission was properly recorded. Consequently, the trial court correctly rendered judgment based on these admissions, as a forged deed is void and transfers no title, making the derived TCTs likewise null and void. The respondent Juani was not denied his day in court; he actively participated in the pre-trial where the admissions were made. Therefore, the Partial Decision was valid and the Court of Appeals committed reversible error in overturning it.