G.R. No. L-4358 January 2, 1953
JOSE SAMINIADA, petitioner, vs. EPIFANIO MATA, JULIAN PONCE, and ANGEL H. MOJICA, Judge of the Court of First Instance of Albay, respondents.

FACTS

The case involves a dispute over ownership and possession of a riceland in Libon, Albay. Respondent Epifanio Mata claims to have purchased the land from Julian Ponce, while petitioner Jose Saminiada claims possession under Free Patent Application No. 56140. To simplify proceedings, the court, upon the parties’ petition, designated Public Land Inspector Ramon Rempillo as commissioner to determine if the land in the complaint formed part of Saminiada’s free patent application. Rempillo’s initial report stated the land was the same and had an area of approximately 7 hectares, 5 ares, and 50 centares. Based on this report, the parties entered into a compromise agreement on January 18, 1950. The agreement stipulated that Mata would limit his claim to a western portion of 27,602 square meters, and Saminiada would recognize Mata’s ownership over that portion and retain the remainder. The court rendered a judgment approving this agreement. Subsequently, when Rempillo attempted to segregate the 27,602-square-meter portion for Mata, he discovered his initial area calculation was erroneous due to a wrong scale used, and the total area was only about 5 hectares. This meant Saminiada would be left with only about 1.5 hectares instead of the approximately 5 hectares he believed he would retain based on the initial report. Saminiada filed motions for reconsideration and a petition for relief from judgment, arguing his consent to the compromise was vitiated by error induced by the commissioner’s mistaken report. The trial court denied these motions, primarily on procedural grounds, including that the petition for relief was filed beyond the 60-day period prescribed by the Rules of Court. Saminiada then filed this petition for certiorari.

ISSUE

Whether the trial court committed a grave abuse of discretion in denying Saminiada’s petition for relief from a judgment based on a compromise agreement, where his consent to the agreement was allegedly vitiated by a mutual mistake of fact regarding the total area of the land.

RULING

The Supreme Court granted the petition for certiorari. The Court ruled that the so-called “decision” approving the compromise was not a true judgment on the merits but a recording of a contract between the parties (a consent judgment). Following American jurisprudence, which treats such consent judgments as contracts, the Court held they can be set aside on grounds of fraud or mistake. The Court found that Saminiada’s consent to the compromise was indeed vitiated by a fundamental mistake of fact—the erroneous report of the commissioner regarding the total area of the land—which was relied upon by both parties. This mutual mistake affected the very basis of the agreement, as Saminiada would not have agreed to give up 27,602 square meters had he known the total area was only about 5 hectares, leaving him with a disproportionately small portion. The Court rejected the procedural objections, noting that the period for filing a petition for relief should be counted from the discovery of the mistake (when Rempillo’s second report revealed the error), not from the denial of the first motion for reconsideration. The trial court’s refusal to set aside the agreement under these circumstances constituted an abuse of discretion. The Supreme Court set aside the orders denying the petition for relief and the judgment based on the compromise, and remanded the case to the trial court for further proceedings on the merits.