
SUPREME COURT - THIRD DIVISION
[ G.R. Nos. 262727-28, January 27, 2025 ]
MARIA CLAUDIA BELINDA CANDANO-LIM, PETITIONER, VS. DAVID LIM AND THE REPUBLIC OF THE PHILIPPINES, RESPONDENTS.
Case Summary: Amendment of Pleadings & Judicial Admission
Disclaimer: This is for quick-reading purposes only. We recommend reading the full text of the decision. Also, if you find any areas for improvement, please email us at admin@projectjurisprudence.com.
- This case clarifies the rules on amending pleadings and the nature of judicial admissions in the context of a marriage nullity case involving disputes over a vast conjugal estate. The Supreme Court affirmed that a trial court has broad discretion to allow substantial amendments to a petition, even multiple times and through an oral motion, to ensure that all conjugal properties are properly included and the case is decided on its merits. The Court also held that a party's statement about the legal classification of a property (e.g., as "paraphernal") is a legal conclusion, not a binding judicial admission of fact.
- The Petition: David Lim filed a petition to declare his marriage to Maria Claudia Belinda Candano-Lim null and void. His initial petition grossly understated the value of their conjugal assets.
- The Amendments: After Belinda contested the valuation, David was allowed to file an Amended Petition, and later a Second Amended Petition, progressively increasing the declared value of their conjugal properties.
- The "Admission": During a hearing, the parties manifested that any properties not listed in the amended petition would be considered Belinda's exclusive (paraphernal) property. Based on this, the RTC allowed Belinda to sell one such property.
- The Third Amendment: Later, David orally moved to amend the petition a third time to include newly discovered properties. The RTC granted this motion, prompting Belinda to file a *certiorari* petition with the CA, arguing grave abuse of discretion.
- RTC Orders: The RTC denied Belinda's motion to sell additional properties and allowed David to file a Third Amended Petition to include more conjugal assets.
- Court of Appeals (CA) Ruling: The CA denied Belinda's *certiorari* petition, finding that the RTC did not commit grave abuse of discretion. It held that courts should be liberal in allowing amendments and that the supposed "judicial admission" was a legal conclusion, not a binding statement of fact.
- Did the RTC commit grave abuse of discretion by allowing a third substantial amendment to the petition based on an oral motion?
- Is a party's statement in open court that unlisted properties are "paraphernal" a binding judicial admission that prevents them from later claiming those properties as conjugal?
The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals' decision.
- No Grave Abuse in Allowing Amendment: The RTC acted within its broad discretion. Allowing the amendment via an oral motion was a mere procedural irregularity, not a jurisdictional defect, because Belinda was present and given the opportunity to be heard. The amendment served the higher interest of justice by ensuring all conjugal assets are properly litigated to avoid multiplicity of suits.
- Statement was a Legal Conclusion, Not a Judicial Admission: David's statement that unlisted properties were "paraphernal" was not a binding judicial admission of fact. The determination of whether a property is conjugal or paraphernal is a question of law based on evidence and the Family Code, not something that can be created by a party's admission, especially when that admission contradicts the legal presumption of conjugal ownership.
- Amendment of Pleadings (Rule 10): Courts have broad discretion to allow substantial amendments to pleadings, even after a responsive pleading is filed, to serve the interests of justice, avoid multiplicity of suits, and decide cases on their merits.
- Oral Motions: An oral motion for leave to amend a pleading made in open court is a mere procedural irregularity, not a fatal defect, provided the adverse party is notified and given an opportunity to be heard.
- Judicial Admission: A judicial admission must be a deliberate, clear, and unequivocal statement of a concrete fact within the party's peculiar knowledge. It does not apply to statements of opinion or legal conclusions, such as the classification of property as conjugal or paraphernal.