G.R. No. L-34998 January 11, 1973
CONCHITA CADANO, accompanied by her husband TITO LOPEZ and GERARDO CADANO, plaintiffs-appellees, vs. JUAN CADANO, defendant-appellant.

FACTS

The plaintiffs-appellees, Conchita and Gerardo Cadano, are the children of defendant-appellant Juan Cadano. Upon their mother’s death, they filed Civil Case No. 856 for the liquidation and partition of the conjugal partnership properties. On September 22, 1955, the Court of First Instance of Leyte rendered a judgment based on a compromise agreement submitted by the parties, which detailed the division of specific properties between the heirs and the surviving spouse. Although the agreement was formally presented to the court, the copy in the records lacked the signature of Juan Cadano or his counsel. A copy of this judgment was received by his counsel on September 26, 1955, and no motion for reconsideration or appeal was ever filed to challenge it.
Eight years later, in 1963, the plaintiffs filed Civil Case No. 3417 to enforce the 1955 judgment, alleging that Juan Cadano had failed to deliver their share of the produce from the properties adjudicated to them. They sought payment for their share of the produce since 1955. In his answer, Juan Cadano did not directly deny the existence or terms of the prior judgment but instead raised a pre-existing indebtedness from the plaintiffs as a counterclaim. He later challenged the jurisdiction of the court in Civil Case No. 3417, arguing that the 1955 judgment was void because the compromise agreement it was based upon lacked his signature.

ISSUE

The sole issue is whether the Court of First Instance of Leyte had jurisdiction in Civil Case No. 3417 to revive and enforce its 1955 judgment, which was rendered based on an unsigned compromise agreement.

RULING

The Supreme Court affirmed the lower court’s decision, holding that it had jurisdiction to enforce the 1955 judgment. The legal logic rests on the principle that a compromise agreement is binding from the moment it is entered into, and its validity is not negated by the mere absence of a signature on the written document presented to the court, especially when the parties’ actions demonstrate consent. The Court emphasized that a compromise can be oral, and a subsequent unsigned writing merely serves as evidence of that prior binding agreement. The records showed the agreement was submitted by both parties through their respective counsel for judicial approval, and Juan Cadano never moved to set it aside for fraud, mistake, or duress after receiving the judgment.
Furthermore, the Court ruled that the validity of a final judgment cannot be collaterally attacked, as was attempted in the enforcement proceeding, on grounds other than lack of jurisdiction or fraud apparent on the record. The proper remedy for a party alleging lack of consent to a compromise is a direct attack via a motion for reconsideration, an appeal, or a petition for relief from judgment under Rule 38, none of which were pursued by the appellant. Since the 1955 court had jurisdiction over the subject matter and the parties, and the judgment had long become final and executory, the subsequent court acted within its authority in enforcing it through a revival action. The defense of the plaintiffs’ alleged indebtedness was deemed a separate matter that did not invalidate the prior final judgment sought to be enforced.