GR 102360; (March, 1996) (Digest)
G.R. No. 102360 March 20, 1996
Rosita Domingo, petitioner, vs. Court of Appeals and Araneta Institute of Agriculture, respondents.
FACTS
Petitioner Rosita Domingo was a bona fide tenant-occupant of the Gonzales Estate in Caloocan City. The estate was expropriated by the Republic for resale to the tenants. Administration was later transferred to the Philippine Housing and Homesite Corporation (PHHC). In 1960, the PHHC policy changed, prompting Domingo and 51 other tenants to file an action to compel the PHHC to sell the lots to them. The Araneta Institute of Agriculture (AIA) intervened, claiming rights based on a “Kasunduan” where the tenants had conveyed their rights to AIA.
On November 28, 1961, AIA submitted a Compromise Agreement to the trial court, signed by 13 tenants, including petitioner Rosita Domingo. The agreement stipulated that the tenants admitted the allegations in AIA’s complaint and obligated themselves to convey their titles to AIA upon acquisition, for a purchase price of P5.55 per square meter, payable in installments. The trial court approved the agreement and rendered a partial decision based on it on December 23, 1961.
ISSUE
Whether the Compromise Agreement and the consequent partial decision are valid and binding upon petitioner Rosita Domingo.
RULING
Yes, the Compromise Agreement and the partial decision are valid and binding. A compromise is a contract whereby the parties, by making reciprocal concessions, avoid litigation or put an end to one already commenced. Once approved by the court, it becomes a judgment which has the force of res judicata and is immediately executory. There is no appeal from a judgment rendered upon a compromise, as the parties are presumed to have implicitly waived that right.
The Supreme Court emphasized that a compromise may only be annulled on grounds of vices of consent, such as mistake, fraud, violence, intimidation, undue influence, or forgery. Petitioner, however, failed to properly challenge the judgment on these grounds. She filed an action for annulment based on forgery with the Regional Trial Court of Caloocan City, a court which had no jurisdiction to annul the judgment of a concurrent court. The proper venue was the Court of Appeals, pursuant to BP 129. Her action was dismissed for failure to prosecute, and she did not appeal that dismissal. Consequently, she forfeited her right to challenge the compromise judgment. The Court found no merit in the petition and ordered the enforcement of the 1961 partial decision.