G.R. No. 196171, 199238 & 200213; January 15, 2014
RCBC Capital Corporation vs. Banco de Oro Unibank, Inc. (now BDO Unibank, Inc.)

FACTS

These consolidated petitions originated from arbitration proceedings under a Share Purchase Agreement (SPA) between RCBC Capital Corporation and Equitable PCI Bank (EPCIB). Following a merger, BDO Unibank assumed EPCIB’s liabilities. The arbitration, administered by the International Chamber of Commerce, resulted in a Final Award in favor of RCBC Capital. BDO challenged various aspects of the arbitration process and subsequent court confirmations through multiple petitions before the Supreme Court.
Specifically, G.R. No. 196171 involved a petition to review the Court of Appeals’ decision regarding the confirmation of a Partial Award on costs. G.R. No. 199238 was a certiorari petition against the CA’s refusal to enjoin the execution of the Final Award. G.R. No. 200213 sought review of a CA decision upholding the RTC’s denial of BDO’s request for access to Bankard’s accounting system during the arbitration. The Court had already rendered a Decision on the merits in G.R. Nos. 196171 and 199238, denying both petitions.

ISSUE

Whether the Supreme Court should grant the parties’ Joint Motions for the dismissal of the consolidated petitions based on a compromise settlement.

RULING

Yes. The Supreme Court granted the Joint Motions and dismissed all three petitions with prejudice. The legal logic is grounded in the fundamental principle favoring the amicable settlement of disputes. Compromise agreements are highly encouraged and sanctioned as a means to achieve speedy and inexpensive justice, as well as to decongest court dockets. The Court found that the parties—RCBC Capital, BDO, and the involved shareholders—had, after negotiations, reached a complete and final settlement of all claims and counterclaims arising from the arbitration and the ensuing litigation.
The motions demonstrated that the settlement was voluntarily entered into by the parties with the assistance of their respective counsels, with the mutual aim of renewing business relations. There was no showing of any vitiation of consent, such as fraud, mistake, or duress, that would invalidate the compromise. Consequently, the Court, respecting the parties’ autonomy to dispose of their contentious rights, ordered the dismissal of the cases. The dismissal with prejudice signifies that the settlement is final and bars the re-filing of the same claims, effectively closing and terminating the litigation. This disposition is consistent with the Court’s policy to honor agreements that put an end to pending suits.