G.R. No. 202611 , November 23, 2015
ABNER MANGUBAT, PETITIONER, VS. BELEN MORGA-SEVA, RESPONDENT.

FACTS

On March 5, 1974, Gaudencio Mangubat and Aurelia Rellora-Mangubat filed a Complaint for Specific Performance with Damages against Belen Morga-Seva. The RTC of Pili, Camarines Sur, Branch 31, rendered a Decision on August 27, 1985, which became final and executory after unsuccessful appeals. On September 3, 1998, Gaudencio and his children, as heirs of the deceased Aurelia, filed a Complaint for Revival of the Decision. Gaudencio, assisted by Atty. Reynaldo L. Herrera, and Belen entered into a Compromise Agreement, which the RTC approved in a Decision dated February 23, 2001. The agreement required Belen to pay a specified amount on or before June 30, 2001, after which the plaintiffs would transfer TCT No. 6337 to Belen.
Gaudencio died on January 31, 2002. Abner Mangubat, one of the heirs, moved to substitute his father, which the RTC granted for purposes of execution only. Belen made her payment to Atty. Herrera on December 18, 2003. Alleging that the heirs refused to convey the title, the RTC directed Abner to surrender the owner’s copy and the Clerk of Court to execute a deed of conveyance. Abner terminated Atty. Herrera’s services and, through a new counsel, filed a Motion to Declare the Amicable Settlement Null and Void, arguing Gaudencio lacked authority to bind the heirs. Two other heirs, Ruth Mangubat Parcia and Job Mangubat, filed a manifestation dissenting from Abner’s action and seeking to receive their shares. Belen also contested Abner’s capacity, noting he was disinherited in a probate proceeding.
The RTC denied Abner’s motion, finding he was not a real party in interest due to his disinheritance and lack of authority to represent the other heirs, and that the heirs’ inaction for almost four years amounted to ratification. The RTC subsequently issued an Order dated September 25, 2006, divesting the plaintiffs of ownership of the property covered by TCT No. 6337 and vesting it in Belen, pursuant to the final Compromise Agreement, after Abner refused to surrender the title. This order became final. Abner filed a Petition for Annulment of Final Order with the CA, which was dismissed. His motion for reconsideration was also denied.

ISSUE

Whether the Court of Appeals erred in dismissing the Petition for Annulment of Judgment, thereby affirming the RTC’s orders which enforced the Compromise Agreement and divested the heirs of the property.

RULING

The Supreme Court denied the Petition for Review on Certiorari and affirmed the assailed CA Resolutions. The Court held that a judgment based on a compromise agreement is immediately final and executory, and not subject to appeal. It can only be assailed if it is void or voidable. The RTC Decision approving the Compromise Agreement had long become final. The RTC’s subsequent orders, including the September 25, 2006 Order, were merely issued to execute the final judgment, particularly to compel the surrender of the title and effect the conveyance after Abner’s refusal to comply. The RTC retained jurisdiction to enforce and execute its final judgment. The Court found no grave abuse of discretion by the RTC, as its orders were in accordance with the Rules of Court to achieve the end of execution. The Petition was denied for lack of merit.