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CANDANO-LIM V. LIM [ G.R. Nos. 262727-28, January 27, 2025 ]
MARIA CLAUDIA BELINDA CANDANO-LIM
V.
DAVID LIM AND THE REPUBLIC OF THE PHILIPPINES
G.R. NOS. 262727-28, JANUARY 27, 2025
Summary of Doctrines
- The granting of leave to file an amended pleading is a matter particularly addressed to the sound discretion of the trial court. Courts should be liberal in allowing amendments to avoid multiplicity of suits and to decide cases on the merits.
- An oral motion for leave to amend a pleading, made in open court in the presence of the adverse party, should be considered a mere irregularity that does not deprive the court of its authority to act. This is consistent with the principle of liberal construction of the Rules of Court to promote the just, speedy, and inexpensive disposition of actions.
- A judicial admission must be a deliberate, clear, and unequivocal statement of a party about a concrete fact within that party's knowledge, not a matter of law. A statement on the legal character of a property (e.g., whether it is paraphernal or conjugal) is a mere legal conclusion and does not constitute a binding judicial admission.
- Ownership and title to property cannot be created by mere judicial admission. The nature of a property as conjugal or exclusive is determined by law and requires a review of facts and evidence.
- A trial court, in the exercise of its sound discretion, may relieve a party from the consequences of a judicial admission for strong reasons. The court's decision to ensure a full adjudication of the controversy between the parties, to serve the ends of justice, and to avoid multiplicity of suits are considered valid reasons to relieve a party from an alleged admission.
MARIA CLAUDIA BELINDA CANDANO-LIM
V.
DAVID LIM AND THE REPUBLIC OF THE PHILIPPINES
G.R. NOS. 262727-28, JANUARY 27, 2025
FACTS:
Petitioner Belinda Candano-Lim and respondent David Lim were married in 1971. David filed a petition for the declaration of nullity of their marriage, but in his initial petitions, he failed to disclose the true value and extent of their conjugal properties. He was subsequently allowed by the Regional Trial Court (RTC) to file a Third Amended Petition, which included more properties. Belinda challenged this, arguing that David's repeated amendments caused inexcusable delay and that his previous "admission" that properties not listed in his earlier petition were paraphernal should be binding. She also sought a special order to sell some of these properties, which was denied by the RTC. The Court of Appeals (CA) affirmed the RTC’s rulings, prompting Belinda to file this petition with the Supreme Court.
ISSUE:
The core issue was whether the Court of Appeals committed a reversible error in holding that the Regional Trial Court did not act with grave abuse of discretion when it (1) allowed David Lim to file a substantially amended petition for a third time, and (2) denied Belinda Candano-Lim's motion for a special order to sell properties.
RULING:
The Supreme Court denied the petition and affirmed the CA’s decision. The Court held that the RTC did not commit grave abuse of discretion. The Court explained that the granting of leave to amend a pleading is a matter of sound judicial discretion, and courts should be liberal in allowing amendments to avoid multiplicity of suits and to ensure that cases are decided on their merits. The Court also ruled that an oral motion for leave to amend, made in open court with the adverse party present, is a mere irregularity that does not affect the court's authority.
Furthermore, the Court clarified that David Lim's earlier statement about the paraphernal nature of unlisted properties was not a binding **judicial admission**. A judicial admission must be a statement of a concrete fact, not a legal conclusion. The nature of a property as conjugal or paraphernal is a question of law that requires a review of facts and evidence. A spouse's exclusive ownership of a property cannot be created by mere judicial admission. The Court found that the RTC acted correctly in allowing David to present evidence on the nature of the properties, as this would lead to a full and just adjudication of the case.