G.R. No. L-18328 December 17, 1966
DIOSDADA SABINO, plaintiff-appellee, vs. CONRADO CUBA, defendant-appellant.

FACTS

On September 29, 1959, Diosdada Sabino filed a complaint for forcible entry and detainer in the Justice of the Peace Court of Albuera, Leyte, against Conrado Cuba, alleging that on May 25, 1959, Cuba dispossessed her of one-third of a parcel of land she owned, containing 2.9500 hectares, as described under Tax Declaration No. 2960 in the name of her father, Floro Sabino. The Justice of the Peace Court ruled in favor of Sabino. Cuba appealed to the Court of First Instance of Ormoc City. On January 13, 1960, the parties entered into an amicable settlement, signed by them and their counsel, wherein Cuba recognized Sabino’s absolute ownership and possession of the entire property under Tax Declaration No. 2960, including the litigated portion, in exchange for Sabino paying him P250.00. The court approved this settlement and rendered judgment in accordance with it. Sabino paid the P250.00, and Cuba delivered the fruits of the land to her. On May 20, 1960, Cuba filed a motion to modify the judgment, claiming that on May 19, 1960, Sabino demanded possession of an additional portion of the property (which he had possessed since 1948) that was not part of the original forcible entry case, and he only then learned it was part of the land under Tax Declaration No. 2960. The court appointed a commissioner to inspect the land. The commissioner’s report identified the litigated portion (subject of the settlement) and a separate portion (“C”) that Cuba possessed and was not originally litigated but which Sabino took after the settlement. The court approved the commissioner’s report. Sabino moved for reconsideration, arguing the report was inaccurate and the court had no jurisdiction to alter a final judgment. The court denied her motion. Sabino appealed directly to the Supreme Court.

ISSUE

Whether the Court of First Instance had jurisdiction to reopen the case and modify its judgment based on a compromise agreement after that judgment had become final and had been executed.

RULING

No. The Supreme Court set aside the lower court’s orders appointing the commissioner, approving his report, and denying reconsideration. The Court held that a judgment based on a compromise agreement has the effect and authority of res judicata under Article 2037 of the Civil Code and is immediately final and executory. It settles the parties’ rights conclusively and cannot be disturbed except for vices of consent or forgery. The Court found that Cuba, having signed the settlement with his counsel, could not claim mistake as to its contents. Furthermore, by petitioning for execution to collect the P250.00, receiving payment, delivering the fruits, and initially promising not to disturb Sabino’s possession, Cuba was estopped from questioning the agreement’s terms. The Court also noted that in case of a discrepancy between the area and boundaries stated in a complaint, the boundaries prevail. Since the judgment was final and fully executed concerning Sabino’s obligation, the lower court’s jurisdiction was limited to enforcing the judgment, not modifying it.