Eastern Shipping Lines, Inc., vs BPI/MS Insurance Corporation
G.R. No. 182864, January 12, 2015
Facts: A complaint for actual damages amounting to US$17,560.48 was filed by herein respondents against Eastern Shipping Lines, Inc., (ESLI) covering steel subject to its shipment. Petitioner insisted that it was through the management of the stevedore where the damages have been incurred. For failure to reach settlement on the legal issues it was submitted to trial and during the pre-trial several stipulations of facts were admitted. The trial court ruled in favor of the respondents. ESLI appealed disputing its liability as to the damaged goods and invoking further the validity of the contents of the bill of lading.
Issue: Whether or not admissions made during the pre-trial as to the validity of the bills of lading are binding.
Ruling: Yes. Judicial admissions are legally binding on the party making the admissions. Pre-trial admission in civil cases is one of the instances of judicial admissions explicitly provided for under Section 7, Rule 18 of the Rules of Court, which mandates that the contents of the pre-trial order shall control the subsequent course of the action, thereby, defining and limiting the issues to be tried. In Bayas v. Sandiganbayan, this Court emphasized that:
Once the stipulations are reduced into writing and signed by the parties and their counsels, they become binding on the parties who made them. They become judicial admissions of the fact or facts stipulated. Even if placed at a disadvantageous position, a party may not be allowed to rescind them unilaterally, it must assume the consequences of the disadvantage.
Moreover, in Alfelor v. Halasan, this Court declared that:
A party who judicially admits a fact cannot later challenge that fact as judicial admissions are a waiver of proof; production of evidence is dispensed with. A judicial admission also removes an admitted fact from the field of controversy. Consequently, an admission made in the pleadings cannot be controverted by the party making such admission and are conclusive as to such party, and all proofs to the contrary or inconsistent therewith should be ignored, whether objection is interposed by the party or not. The allegations, statements or admissions contained in a pleading are conclusive as against the pleader. A party cannot subsequently take a position contrary of or inconsistent with what was pleaded. (Citations omitted)
The admission having been made in a stipulation of facts at pre-trial by the parties, it must be treated as a judicial admission. Under Section 4, of Rule 129 of the Rules of Court, a judicial admission requires no proof.