G.R. No. L-6259, L-6260, L-6261, November 13, 1911
THE MANILA RAILROAD COMPANY, plaintiff-appellant, vs. FRANCISCO ARZADON, ET AL., defendants-appellees. (Consolidated Cases)

FACTS

The Manila Railroad Company initiated three expropriation cases in the Court of First Instance of Pangasinan to acquire lands for its railway line from Dagupan to San Fabian. Commissioners were appointed to appraise the land values. On August 31, 1909, the commissioners submitted their report. During the hearing on January 19, 1910, the parties, through their attorneys, appeared before the court and agreed to the commissioners’ report. They presented the report to the court and requested that judgment be entered in conformity with it. The court, finding the report correct and the valuations just, approved the report and rendered judgment accordingly. Subsequently, the plaintiff moved for a new trial on grounds including newly discovered evidence and that its consent to the judgment was given under a mistake, claiming its attorney signed the stipulation without fully understanding its contents. The trial court denied these motions.

ISSUE

Whether the trial court erred in denying the plaintiff’s motions for a new trial and in affirming the judgment based on the commissioners’ report, given that the plaintiff had consented to the judgment.

RULING

No, the trial court did not err. The Supreme Court affirmed the judgment of the lower court. The Court held that the judgment was entered by consent of the parties. A judgment by consent has the same force and effect as any other judgment and is conclusive upon the parties. It cannot be appealed or set aside except on grounds of fraud, lack of consent, or insertion of terms not agreed upon. The plaintiff’s claim of mistake in giving consent was without merit, as its attorney voluntarily signed the stipulation approving the report and requesting judgment. The proper remedy for the plaintiff, if it believed consent was given by mistake, was an application to open the judgment, not an appeal. Since the trial court did not abuse its discretion in denying the motions to open the judgment, the appeal was unsustainable. All other factual issues antedating the judgment were deemed settled by the consent agreement and could not be raised on appeal.