Roberto G. Alarcon, Petitioner, V. The Court of Appeals and Bienvenido JUANI, Respondents. Kapunan, J

ROBERTO G. ALARCON, Petitioner, v.
THE COURT OF APPEALS and BIENVENIDO

JUANI, Respondents.
KAPUNAN, J.
Petition for Review on Certiorari (Rule 45).
DISPOSITIVE:
WHEREFORE, the petition is GRANTED. The decision of the Court of Appeals is REVERSED
and the Partial Decision rendered by the Regional Trial Court on August 1, 1986 is
REINSTATED.
SO ORDERED.
SUMMARY: At a pre-trial conference, the two opposing parties, represented by their

counsels, admitted that the Deed of Sale concerning a portion of Roberto Alarcon’s parcel of
land was forged. The SC ruled that the defendants were bound by their admissions and
notice to their counsels. Hence, their Certificates of Title, being based on a forged Deed of
Sale, were patent nullities.
DOCTRINE: Admissions clearly made during the pre-trial conference are conclusive upon
the parties making them. The purpose of entering into a stipulation of facts or admissions of
facts is to expedite trial and to relieve the parties and the court, as well, of the costs of
proving facts which will not be disputed on trial and the truth of which can be ascertained
by reasonable inquiry.
 On June 17, 1985, Roberto Alarcon filed a complaint for the annulment of a deed of
sale with damages against Bienvenido Juani, Edgardo Sulit and Virginia Baluyot as
defendants.
 Tomas Alarcon, petitioner’s father, sold on the basis of a Special Power of Attorney
2,500 sq.m. of the latter’s land to Juani and other parties while Roberto was in
Brunei.
 The defendants were able to register the sale, cancel the title of Robert, and have
new titles issued in their names.
 Roberto Alarcon prayed for the nullification of the sale contending that, among
others, his father’s signature on the Deed of Sale was forged.
 After all the issues were joined, the trial court set the case for pre-trial conference
on June 3, 1986 which was continued on August 1, 1986.
 During the pre-trial conference, the parties, represented by their counsel, made
some admissions of facts – with the truth of the forged deed of sale being one of
them.
RTC
Dismissed petitioner’s complaint as against Juani.
On August 19, 1991, the trial court issued an order granting petitioner’s motion for a writ of
execution of the Partial Decision.
For failure of the defendants to interpose an appeal from the Partial Decision, the same
became final and executory. However, the judgment could not be executed because the
defendants allegedly refused to surrender their respective Owner’s Duplicate of Transfer
Certificates of Title issued to them by the Register of Deeds.
COURT OF APPEALS
On April 17, 1995, herein private respondent Bienvenido Juani filed with the Court of
Appeals a petition for the annulment of the Partial Decision rendered by the trial court –
granted.
ISSUES & RATIO:
 Whether or not defendant Juani was properly represented by Counsel - YES.
 “x x x (d)uring the pre-trial of the case conducted on June 3, 1986 and August 1,
1986, all the parties and their respective counsels appeared.
 The transcript of the stenographic notes of the hearing conducted on June 3, 1986
would show that Juani, together with defendant Baluyot, was represented by
counsel, Atty. Venancio Reyes. A reading of the TSN of the pre-trial would also reveal
that Atty. Reyes was not in any way remiss of his duties in protecting the interests of
his clients. Documents/evidence were presented, objections/ denials for lack of
knowledge were interposed and admissions were properly made. In all of the
scheduled hearings before the trial court, Juani was always represented by counsel.
 The bare fact is that the Partial Decision was rendered after the parties and their
counsels entered into a stipulation of facts. Here, it was admitted that the document
or the deed of sale which was made the basis for the issuance of titles in the names
of Bienvenido Juani, Virginia Baluyot and Edgardo Sulit was falsified. The deed of
sale executed by Tomas Alarcon was a forgery considering that: (a) the signature of
Tomas Alarcon was false; (b) the monetary consideration was unconscionably low;
and (c) the signature of the notary public at-testing to the sale was also forged.
 The admissions were clearly made during the pre-trial conference and, therefore,
conclusive upon the parties making it. The purpose of entering into a stipulation of
facts or admissions of facts is to expedite trial and to relieve the parties and the
court, as well, of the costs of proving facts which will not be disputed on trial and the
truth of which can be ascertained by reasonable inquiry.

Roberto G. Alarcon, Petitioner, V. The Court of Appeals and Bienvenido JUANI, Respondents. Kapunan, J

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Roberto G. Alarcon, Petitioner, V. The Court of Appeals and Bienvenido JUANI, Respondents. Kapunan, J

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ROBERTO G. ALARCON, Petitioner, v.

THE COURT OF APPEALS and BIENVENIDO

Petition for Review on Certiorari (Rule 45).

SUMMARY: At a pre-trial conference, the two opposing parties, represented by their

Dismissed petitioner’s complaint as against Juani.

ISSUES & RATIO:

 Whether or not defendant Juani was properly represented by Counsel - YES.

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