GR 168840; (December, 2010) (Digest)
G.R. No. 168840 ; December 8, 2010
ENRIQUE MIGUEL L. LACSON, Petitioner, vs. MJ LACSON DEVELOPMENT COMPANY, INC., Respondent.
FACTS
Respondent MJ Lacson Development Company, Inc. filed a Complaint for Injunction, Accounting, and Damages against its former president, petitioner Enrique Miguel Lacson. The corporation alleged that petitioner, after being replaced in a board meeting, refused to relinquish his position, continued to manage the corporate hacienda, and withheld proceeds from sugar sales amounting to millions of pesos. The Regional Trial Court (RTC) issued a temporary restraining order against petitioner.
Subsequently, the parties entered into an Amicable Settlement, which was approved by the RTC and had the effect of a final judgment. Under the settlement, petitioner agreed to execute a promissory note for cash advances, secured by a pledge of his corporate shares, and to pay in installments. He also agreed to lease corporate farm equipment and land. Later, petitioner filed a Motion for Partial Modification, seeking to reduce his monetary obligation, which the RTC denied. The Court of Appeals affirmed the denial, prompting this petition.
ISSUE
Whether the Court of Appeals erred in affirming the RTC’s denial of the Motion for Partial Modification of the Amicable Settlement.
RULING
The Supreme Court denied the petition and affirmed the appellate court’s decision. The Court held that an amicable settlement, once judicially approved, attains the force of res judicata and is final and executory. It cannot be modified or altered, except for vices of consent or forgery, as it represents a binding contract between the parties. Petitioner’s claim of economic duress—that he signed due to financial pressure and the restraining order—was a factual issue improperly raised in a petition for review on certiorari, which only reviews questions of law.
The Court emphasized that a petition under Rule 45 cannot warrant a re-examination of factual findings, such as the validity of consent. The lower courts’ factual determination that the settlement was voluntarily entered into was thus conclusive. Consequently, no legal basis existed to modify the final and executory agreement.