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Atlas Consolidated Mining & Development Corp. vs Commissioner of Internal Revenue (CIR)

ATLAS CONSOLIDATED MINING& DEVELOPMENT CORPORATION, petitioner, vs. COMMISSIONER OF INTERNAL REVENUE, respondent.

G.R. No. 134467 | 1999-11-17

D E C I S I O N

PANGANIBAN, J.:

A litigation is neither a game of technicalities nor a battle of wits and legalisms; rather, it is an abiding search for truth, fairness and justice. While stipulations of facts are normally binding on the declarant or the signatory thereto, a party may nonetheless be allowed to show that an admission made therein was the result of a "palpable mistake" that can be easily verified from the stipulated facts themselves and from other incontrovertible pieces of evidence admitted by the other party. A patently clerical mistake in the stipulation of facts, which would result in falsehood, unfairness and...