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REPUBLIC GLASS CORPORATION v. LAWRENCE C. QUA

This case has been cited 3 times or more.

	GR No. 183446 2012-11-13	REPUBLIC v. ESTATE OF HANS MENZI PEREZ, J.
Having been made by their executor during the trial of the case on the merits, these declarations are binding, at least insofar as the Estate is concerned. Pursuant to Section 4, Rule 129 of the Revised Rules on Evidence, an admission, verbal or written, made by a party in the course of the proceedings in the same case does not require proof. It may be made: (a) in the pleadings filed by the parties; (b) in the course of the trial either by verbal or written manifestations or stipulations; or (c) in other stages of judicial proceedings, as in the pre-trial of the case.[50] When made in the same case in which it is offered,[51] "no evidence is needed to prove the same and it cannot be contradicted unless it is shown to have been made through palpable mistake or when no such admission was made."[52] The admission becomes conclusive on him, and all proofs submitted contrary thereto or inconsistent therewith should be ignored, whether an objection is interposed by the adverse party or not.[53] Absent any showing in the record that the above-quoted declarations were made by Montecillo through palpable mistake, the Republic correctly argues that they are binding upon the Estate which, for said reason, is precluded from claiming that the funds deposited under TDC Nos. 162828 and 162829 came from the 1984 sale of Bulletin shares to US Automotive.
	GR No. 183196 2009-08-19	CHONA ESTACIO v. PAMPANGA I ELECTRIC COOPERATIVE CHICO-NAZARIO, J.
In this case, the essential elements of estoppel are inexistent.[42]
	GR No. 156052 2008-02-13	SOCIAL JUSTICE SOCIETY v. JOSE L. ATIENZA CORONA, J.
While it is true that a party making a judicial admission cannot subsequently take a position contrary to or inconsistent with what was pleaded,[83] the aforestated rule is not applicable here. Respondent made the statements regarding the ordinances in civil case nos. 03-106379 and 06-115334 which are not "the same" as this case before us.[84] To constitute a judicial admission, the admission must be made in the same case in which it is offered.