G.R. No. 204106 . November 17, 2021
OLIVIA D. LEONES, PETITIONER, VS. HON. CARLITO CORPUZ, IN HIS CAPACITY AS PRESIDING JUDGE OF BRANCH 27, REGIONAL TRIAL COURT, CITY OF SAN FERNANDO, LA UNION, AND HON. MINDA FONTANILLA, IN HER CAPACITY AS MUNICIPAL MAYOR OF BACNOTAN, LA UNION, RESPONDENTS.

FACTS

Petitioner Olivia D. Leones was appointed Municipal Treasurer of Bacnotan, La Union in February 1994. In December 1996, she was temporarily detailed to the Office of the Provincial Treasurer of La Union, during which period she was not paid her Representation and Transportation Allowances (RATA). After a series of legal actions, the Court of Appeals, in a Decision affirmed by the Supreme Court in G.R. No. 169726 , ordered the payment of her RATA from December 1996 up to the present during her reassignment. This decision became final and executory on August 6, 2010, but the RATA remained unpaid. Leones then filed a petition for mandamus (Special Civil Action No. 007-11) against the incumbent mayor, Rufino Fontanilla. The parties entered into a Compromise Agreement dated May 30, 2011, wherein Mayor Fontanilla agreed to pay Leones the total amount of PHP 1,055,109 representing her unpaid RATA from January 1997 until May 2011, with full payment on or before June 30, 2011. In return, Leones obligated herself to retire from her position on May 31, 2012. The RTC approved this agreement and rendered a Compromise Judgment on June 23, 2011. The Municipality completed its payments on May 31, 2012. Subsequently, Leones was dropped from the payroll effective May 31, 2012. Mayor Fontanilla filed a motion for issuance of a writ of execution of the compromise agreement, which the RTC granted. Leones moved to quash the writ, claiming the compromise judgment was null and void for being contrary to public policy and for modifying the unconditional decisions of the higher courts. The RTC denied her motion in its September 12, 2012 Order, upholding the compromise judgment and ordering her to comply, threatening contempt for further refusal.

ISSUE

Whether the Regional Trial Court committed grave abuse of discretion in issuing the September 12, 2012 Order denying petitioner’s motion to quash the writ of execution of the Compromise Judgment.

RULING

No, the Regional Trial Court did not commit grave abuse of discretion. A writ of certiorari requires a showing that the tribunal acted without or in excess of jurisdiction, or with grave abuse of discretion amounting to lack or excess of jurisdiction. Grave abuse of discretion exists when the act is done in a capricious, whimsical, arbitrary, or despotic manner equivalent to lack of jurisdiction. The RTC’s approval of the Compromise Agreement and the subsequent issuance of the writ of execution were based on the parties’ voluntary agreement. A compromise agreement, once approved by the court, has the force of res judicata and is immediately executory. The RTC correctly found that the earlier Supreme Court Decision in G.R. No. 169726 did not constitute res judicata in the mandamus case (SCA No. 007-11) as the two cases involved different parties and prayed for different reliefs. Furthermore, the RTC correctly held that no public policy was violated by the agreement for Leones to retire, as public office is not property under the constitutional guarantee of due process. The RTC acted within its jurisdiction in enforcing the compromise agreement voluntarily entered into by the parties. Therefore, the petition for certiorari and prohibition is without merit.