Case Name: Heirs of Franco vs.

CA By: Tangonan
GR No. 123924 Topic: Declaration Against Interest
Date: 11 December 2003
FACTS:
This is a petition for review on certiorari seeking to overturn the CAs decision which reversed that of the RTC issuing
in the name of Miguel Franco a new TCT for half of the lot which originally belonged to Quintin Franco.
Quintin died intestate and his brother, Miguel, filed a petition for the issuance of letters of administration, but Faustina,
their sister, opposed the same on the ground that Miguel was unfit.
Notwithstanding, the RTC appointed Miguel as special admin on 3 Dec. 1969.
In 1973, Faustina and the other heirs of Quintin filed to remove Miguel as special admin. Later, in lieu of a General
Power of Admin (which transferred in the name of Miguel half of the property) executed by Quintin, Miguel was
issued a new TCT fir the said half of the property, but was later removed as special admin due to his conflicting
interests thereon.
CA later reverse the same because of the fact that Miguel succeeded in registering the property in his name thru fraud,
surreptious conduct, and bad faith.

ISSUE/S: W/N the CA erred in reversing the RTCs decision.

RULING: NO
In the original action by Miguel, he explicitly declared that the property wholly belonged to Quintin while staying silent about
his claim to of the same, which he allegedly acquired while the latter was still alive. He asserted his claim belatedly (4 yrs
after making the declaration that the property belonged entirely to the deceased). It wasnt only a declaration against interest,
but also a judicial admission. However, a judicial admission may still be stricken off if thers showing that it was made thru
palpable mistake.

Herein, theres no showing that Miguel made the admission thru palpable mistake. Hence, from the substantive and procedural
standpoint alike, the statement of Miguel, being both a declaration against his interest (the best evid which affords the greatest
certainty of the facts in dispute) & a judicial admission, should be afforded the full evidentiary value it deserves. Thusly, the CA
didnt err in reversing the RTCs decision.