G.R. No. 204447 , May 03, 2021
MARIA MAGDALENA V. AROMIN ALSO KNOWN AS MARIA V. AROMIN, PETITIONER, VS. HEIRS OF SPOUSES WILFREDO AND LEONILA SOMIS, NAMELY: WILFREDO A. SOMIS, JR., VIOLITA SOMIS-FLORES, ELEANOR SOMIS FLORES, OLIVE SOMIS DE CASTRO, DELIA SOMIS-SORIANO, LALAINE SOMIS-DE LA CRUZ, CELSO A. SOMIS, AND ALL PERSONS CLAIMING RIGHTS UNDER THEM, RESPONDENTS.

FACTS

Petitioner Maria Magdalena Aromin owned three parcels of land with her deceased husband. In 2007, she discovered that two lots (Lot A and Lot C) had been sold to the spouses Wilfredo and Leonila Somis via a 1971 Deed of Sale. She filed a Complaint for Annulment of Documents. During the proceedings, the parties entered into a Compromise Agreement dated November 28, 2007, wherein Maria (through her son Briccio as attorney-in-fact) and Leonila (through her son Celso as attorney-in-fact) agreed that Lot A would belong to Maria and Lot B would belong to the Somises. The Regional Trial Court (RTC) approved this agreement in a January 17, 2008 Decision, which became final and executory. A Writ of Execution was issued. Maria later filed a motion to correct the Compromise Agreement, claiming she intended to give Lot C, not Lot B, to the Somises, and that the Property Identification Number (PIN) was erroneous. The RTC granted her motion, but the Court of Appeals (CA) reversed this in a 2010 Decision, reinstating the original Compromise Agreement. Maria subsequently filed a Petition for Annulment of Judgment before the CA, arguing the Compromise Agreement was void due to lack of authority of Celso Somis to represent Leonila, lack of meeting of the minds (as the wrong lot was described), and extrinsic fraud/negligence of her former counsel. The CA denied her petition. Maria appealed to the Supreme Court.

ISSUE

Whether or not the Compromise Agreement between the parties is valid and binding.

RULING

The Supreme Court denied the petition and affirmed the CA Resolutions. The Compromise Agreement is valid and binding. The Court held that the RTC’s January 17, 2008 Decision approving the Compromise Agreement had long become final and executory. A final and executory judgment is immutable and unalterable. The Court found that the essential elements of a contract under Article 1318 of the Civil Code were present: consent, a certain object, and a cause. There was a meeting of the minds as the parties mutually agreed to transfer the specified properties. Maria’s claim of a mistake in the property description was not substantiated, and she or her representative had the duty to exercise due diligence in reviewing the agreement before signing. The Court also ruled that the alleged lack of a Special Power of Attorney for Celso Somis did not invalidate the contract, as Leonila’s subsequent acts ratified his authority. Furthermore, the negligence of Maria’s former counsel, Atty. Benilda Indasen, did not constitute extrinsic fraud that would warrant annulment of judgment, as extrinsic fraud requires a fraudulent scheme that prevents a party from having their day in court, which did not occur here as Maria actively participated in the proceedings.