Final and binding

This a case about a judgment based on a Compromise Agreement which has become final and executory. The issue raised here is whether said decision can still be questioned or reopened if it is erroneous? This is the case of Marina.

Marina and her deceased husband Rudy owned three parcels of land in two towns of a Northern Luzon province, particularly the following: (1) a parcel of unirrigated rice land with an area of 2,827 square meters (Lot A); (2) a parcel of unirrigated rice land with an area of 1,228 square meters (Lot B); and (3) a parcel of land with an area of 1,328 square meters with a 300 square meter house built thereon (Lot C).

When Marina asked her son Cardo to pay the realty tax thereon, he discovered that Lots A and C were sold to the spouses Wally and Lina (the Spouses Solis) through Deeds of Sale with a Right to Repurchase supposedly signed by Marina and Rudy.

So Marina filed a Complaint for Annulment of Documents with damages alleging that she did not sign the Deed of Sale transferring Lot C to the spouses, hence it is void. After the spouses Solis received the complaint and filed their answer, the parties entered into a Compromise Agreement wherein Lina Solis agreed that Lot A shall belong to Marina and in turn Marina Agreed that Lot B shall belong to Lina. The Compromise Agreement was signed by Cardo as Attorney-in-Fact of Marina and by Lina’s son Lando, as Attorney-in-Fact of Lina, assisted by their respective lawyers. It was later on approved by the trial court which became final by reason of which a Writ of Execution was issued by the court.

Subsequently, however, Marina filed a Motion to Set Aside the Order granting the Writ of Execution, claiming that she intended to give Lot C and not Lot B to the spouses Solis. She claimed that the description of the property given to the spouses under the Compromise Agreement was erroneous. The RTC granted the motion and ordered that Lot B in the Compromise Agreement be changed to Lot C. The Spouses Solis filed a Motion for Reconsideration, but it was denied. So the couple appealed to the Court of Appeals (CA) by Petition for Certiorari. Said Petition was granted, declaring that the Compromise Agreement has been approved by the Court and is therefore final and executory which must be implemented strictly in accordance with its term and conditions.

So Marina appealed to the Supreme Court when her motion for reconsideration was denied by the CA. She claims that the Compromise Agreement is void because there was no meeting of the minds of the parties as she intended to transfer Lot C and not Lot B. Was Marina correct?

The Supreme Court said no. It affirmed the CA decision. According to the SC, a definitive and final judgment, however erroneous, is no longer subject to change or revision. It is beyond dispute that the Compromise Agreement was approved by the Trial Court and has become final. Consequently a Writ of Execution was already issued. In said Agreement, it was clear that the contracting parties mutually agreed to transfer to each other the properties indicated therein. Moreover, if indeed there was mistake on which property should be transferred to the spouses Solis, Marina should have availed of her remedies immediately. The CA also aptly denied the Petition for Annulment of Judgment because an annulment of judgment may be based only on the grounds of extrinsic fraud and lack of jurisdiction. In this case jurisdiction over plaintiff Marina was acquired by the RTC by her filing of the complaint; and over the spouses by the service of summons.

Likewise jurisdiction over the subject matter of the Complaint was acquired by the RTC because the action to annul a contract and for re-conveyance is incapable of pecuniary estimation and thus within the jurisdiction of the RTC.

So the Compromise Agreement is valid and binding between the parties and the decision of the RTC should be respected since the grounds to annul the same are non-existent. The CA decision is therefore affirmed (Aromin etc vs. Heirs of Spouse Somis, G.R. 204447, May 3, 2021).

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On Election Day May 9, 2022, let us help and support the sincere, honest, dedicated and idealistic men and women who are candidates for various public offices. Let us vote for them, more particularly my son Jopet Sison, who is a candidate for senator.