AC 9426; (August, 2020) (Digest)
G.R. No. 219431 , August 24, 2020
Spouses Roberto and Beatriz Garcia, Petitioners, vs. Spouses Arnel and Cricela Soriano, Respondents.
FACTS
Respondents filed an action for Consolidation of Ownership against petitioners. The parties entered into a Compromise Agreement, judicially approved on June 4, 2007. It granted petitioners a grace period of six months to one year to pay P300,000.00 to repurchase two parcels of land. Failure to pay would obligate petitioners to deliver one specific lot (Lot 3) to respondents. Petitioners failed to pay within the stipulated period. On January 30, 2009, the RTC, noting petitioners’ plea and with respondents’ alleged permission, issued an Order extending the period to pay until April 30, 2009. Petitioners later manifested readiness to pay, but respondents refused acceptance, arguing the judgment was already final.
ISSUE
Whether the Regional Trial Court (RTC) committed grave abuse of discretion in issuing the writ of execution to enforce the judgment based on compromise, despite its subsequent Order extending the period for petitioners to pay.
RULING
No. The Supreme Court affirmed the Court of Appeals’ decision granting the writ of execution. A judgment based on a court-approved compromise agreement is immediately executory and final. It has the force of res judicata and cannot be appealed, modified, or altered except for vices of consent or forgery. The RTC’s Order dated January 30, 2009, which purported to extend the payment period, was a nullity. A final and executory judgment is immutable. The trial court lost jurisdiction to amend its terms after the judgment based on compromise became final. The alleged consent by respondents to the extension, given during a hearing, was insufficient to constitute a new, binding agreement as it was not reduced to writing, signed by the parties, and approved by the court as a novation or new compromise. Equity cannot be invoked to override settled law and the clear terms of a final judgment. Petitioners’ failure to comply with the original agreement justified the execution.