GR 130623; (February, 2008) (Digest)
G.R. No. 130623 ; February 29, 2008
LOREA DE UGALDE, petitioner, vs. JON DE YSASI, respondent.
FACTS
Petitioner Lorea de Ugalde and respondent Jon de Ysasi were married in 1951. They separated in 1957. In 1961, during a custody case (Civil Case No. 4791), they entered into an Amicable Settlement approved by the Court of First Instance (CFI). The agreement stipulated that respondent would pay petitioner P30,000 in full satisfaction of all past and future claims, including her share in any conjugal property or inheritance. Petitioner acknowledged receipt and executed a quitclaim.
In 1984, petitioner filed a petition for dissolution of the conjugal partnership of gains before the Regional Trial Court (RTC), seeking her share in respondent’s inheritance from his deceased parents and other relief. Respondent moved for dismissal, arguing the 1961 Amicable Settlement barred the action and that their marriage was void for lack of a license. The RTC dismissed the petition, ruling the marriage was void and, assuming validity, the action was barred by res judicata due to the final compromise agreement. The Court of Appeals affirmed.
ISSUE
Whether the Court of Appeals erred in affirming the dismissal of the petition for dissolution of the conjugal partnership of gains.
RULING
The Supreme Court denied the petition and affirmed the appellate court’s decision. The core legal logic rests on the finality and binding effect of the judicially approved compromise agreement. A compromise agreement, once approved by the court, has the force of res judicata and is conclusive upon the parties. The 1961 Amicable Settlement expressly stated that the P30,000 payment was in full satisfaction of all property claims, including any future share in conjugal property or inheritance. By accepting the payment and executing a quitclaim, petitioner voluntarily extinguished any future claims arising from the marriage.
Consequently, the conjugal partnership, if it ever existed, was deemed dissolved as of the CFI’s approval of the settlement on June 6, 1961. Petitioner’s attempt to seek a share in properties, including an inheritance received by respondent years later, is barred by this final judgment. The Court found it unnecessary to definitively rule on the validity of the marriage based on the alleged absence of a license, as the compromise agreement independently disposed of the case. The defense of laches was also applicable, as petitioner filed her petition 23 years after the compromise became final.