Admissions in barangay proceedings judicial

Admissions in barangay proceedings judicial | Daily Tribune

As a way of nipping cases in the bud, the Supreme Court requires that parties belonging to the same or adjacent barangays must first resort to barangay conciliation proceedings in an effort to forge a compromise agreement. The Lupon Tagapamayapa of the barangay will exert all efforts to make the parties iron out their differences. Note that it cannot decide one way or the other, for the parties. He does not wield judicial powers like judges, to decide on cases. Rather he can only act as mediator, bringing the parties together in the hope that they eventually have a win-win solution. But absent a settlement, all the Lupon can do is issue a certification to that effect and declare that the case is already ripe for the courts to look into.

Here is a key takeaway in the case I am to discuss today. While the proceedings in the barangay conciliation may seem informal and non-litigious, take note that whatever admissions a party makes, can be held against him as a judicial admission. Yes, a judicial admission at that, even if parties are not in judicial proceedings in a court of law.

The dispute I wish to discuss stemmed from land ownership. Both sides claimed ownership over the land, with their own arguments against the other party. It so happened that one party during the barangay proceedings admitted there that he tampered with the deed of sale of the subject land. So when no settlement was had, the case was forwarded to the court. The other party made use of this admission claiming that their adversary himself admitted that he tampered with the deed of sale. After trial, the court ruled against the party who made the admission, highlighting the fact that he himself made such an admission. On appeal to the Court of Appeals, the appellate court again put the blame on the person who made the admission; thus, dismissing said party’s appeal. The case was elevated to the Supreme Court. The Highest Court took note of the factual antecedents and decided against the petitioners. It ruled:

“Even if the consolidated petitions are given due course, they must still fail for petitioners’ failure to prove that the CA erred in affirming the ruling of the RTC in favor of respondents. As aptly observed by the CA:

“In the present case, the findings of the DENR that Aquilino Ramos deliberately tampered his free patent application for Lot No. 12020 carries great weight and should be accorded respect, more so, when Aquilino Ramos failed to rebut such findings. There being no controversion, the presumption of regularity in the performance of official duties applies favorably to the DENR. This means that the DENR’s findings has become conclusive...

“Aside from the findings of the DENR, the Court notes that Aquilino Ramos admitted during the barangay proceedings that he tampered [with] the deed of sale attached in his free patent application to Lot No. 12020. The admission by Aquilino Ramos qualifies as a judicial admission. Since such statement is judicial admission, it does not require proof according to Section 4, Rule 129 of the Rules of Court, which provides:

“SEC. 4. Judicial admissions. — An admission, verbal or written, made by a party in the course of the proceedings in the same case, does not require proof. The admission may be contradicted only by showing that it was made through palpable mistake or that no such admission was made.

“Since there is judicial admission that the deed of sale was tampered [with], then there is no question that the Deed of Sale of Unregistered Land selling Lot 12020 is void. Consequently, the Deed of Sale of Unregistered Land selling Lot 12020 did not transfer ownership of the land to appellants, as Aquilino Ramos had no title or interest to transfer.22 (Citations omitted)

Indeed, “the trial court’s findings of fact are entitled to great weight and will not be disturbed on appeal. ‘The rule finds an even more stringent application where the findings are sustained by the CA.”

“Here, the Court finds no cogent reason to overturn the finding of the RTC, as affirmed by the CA, that the subject Deed of Sale is void for having been tampered with by Aquilino Ramos.”

The facts and quoted salient portion of the decision are from Heirs of Aquilino Ramos et al. v. Prosalita Bagares, et al. (G.R. 271934, 27 November 2024).