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Also, the matters contained in the following were written in accordance with the law, rules, and jurisprudence prevailing at the time of writing and posting, and do not include any future developments on the subject matter under discussion.
AT A GLANCE:
The doctrine of estoppel provides that an admission or representation is rendered conclusive upon the person making it, and cannot be denied or disproved as against the person relying thereon.
The doctrine of estoppel is based upon the grounds of public policy, fair dealing, good faith and justice, and its purpose is to forbid one to speak against its own act, representations, or commitments to the injury of one to whom they were directed and who reasonably relied thereon.
There are three kinds of estoppels, to wit:
(1) estoppel in pais;
(2) estoppel by deed; and
(3) estoppel by laches.
Article 1431 of the Civil Code provides, “through estoppel, an admission or representation is rendered conclusive upon the person making it, and cannot be denied or disproved as against the person relying thereon.
What is the Doctrine of Estoppel?
The doctrine of estoppel has been explained in numerous Supreme Court decisions.
In the case of Philippine Savings Bank vs. Chowking Food Corporation, G.R. No. 177526, July 3, 2008, the doctrine of estoppel was defined as an admission or representation is rendered conclusive upon the person making it, and cannot be denied or disproved as against the person relying thereon. A party may not go back on his own acts and representations to the prejudice of the other party who relied upon them. In the law of evidence, whenever a party has, by his own declaration, act, or omission, intentionally and deliberately led another to believe a particular thing true, to act upon such belief, he cannot, in any litigation arising out of such declaration, act, or omission, be permitted to falsify it.
In the case of Security Bank Corporation vs. Spouses Jose vs. Martel And Olga S. Martel, G.R. No. 236572, November 10, 2020, the Supreme Court explained the intention behind the doctrine of estoppel. The doctrine of estoppel is based upon the grounds of public policy, fair dealing, good faith and justice, and its purpose is to forbid one to speak against its own act, representations, or commitments to the injury of one to whom they were directed and who reasonably relied thereon. The doctrine of estoppel springs from equitable principles and the equities in the case. It is designed to aid the law in the administration of justice where without its aid injustice might result. It has been applied by this Court wherever and whenever the special circumstances of a case demands, and the Court finds it applicable in the instant case.
Types of Estoppel
In the cases of Patricia Zamora Riingen vs. Western Union Financial Services (Hong Kong) Limited, Philippines Representative Office, G.R. No. 252716, March 03, 2021 and Jose C. Go, Gotesco Properties, Inc., et al. vs. Bangko Sentral Ng Pilipinas, et al., July 8, 2015, G.R. No. 202262, the Supreme Court reiterated that there are three kinds of estoppels, to wit:
(1) estoppel in pais;
(2) estoppel by deed; and
(3) estoppel by laches.
Under estoppel in pais, a person is considered in estoppel if by his conduct, representations, admissions or silence when he ought to speak out, whether intentionally or through culpable negligence, “causes another to believe certain facts to exist and such other rightfully relies and acts on such belief, as a consequence of which he would be prejudiced if the former is permitted to deny the existence of such facts.
Under estoppel by deed, a party to a deed and his privies are precluded from denying any material fact stated in the deed as against the other party and his privies. The Supreme Court pointed out in the case of Intestate estate of the late Eulalio Ilagan Bisig, et al. vs. Jesus Ilgagan, et al. that estoppel by deed is a bar which precludes a party from denying the truth of his deed. Prejudice is not an essential element of this kind of estoppel.
Under estoppel by laches, an equitable estoppel, a person who has failed or neglected to assert a right for an unreasonable and unexplained length of time is presumed to have abandoned or otherwise declined to assert such right and cannot later on seek to enforce the same, to the prejudice of the other party, who has no notice or knowledge that the former would assert such rights and whose condition has so changed that the latter cannot, without injury or prejudice, be restored to his former state.
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