G.R. No. L-54043 November 28, 1980
BANGUED WATER DISTRICT, Represented by Edgardo B. Hojilla, Acting Chairman of the Board of Directors, petitioner, vs. HON. HAROLD M. HERNANDO, Presiding Judge, Branch I of the Court of First Instance of the Province of Abra, DR. BEN BRINGAS, et al., respondents.

FACTS

The petitioner, Bangued Water District, filed a petition for certiorari against the presiding judge of the Court of First Instance of Abra and private respondents, including Dr. Ben Bringas. The petition sought to annul or modify the proceedings before the respondent judge and included a prayer for a preliminary injunction to protect the petitioner’s rights pending the proceedings. The underlying dispute originated from Civil Case No. 1257 before the lower court.
Subsequent to the filing of the petition and after the private respondents had submitted their comment, the parties involved in the original civil case entered into a Compromise Settlement. This agreement stipulated that the respondents would undertake a significant improvement project for the Bangued water system and conduct a thorough accounting of the Water District’s funds and materials. In return, the petitioners agreed to waive their claims for damages and accounting. The settlement also detailed a specific schedule for future water rates and established a process for any subsequent rate changes.

ISSUE

Whether the petition for certiorari should be dismissed in light of the Compromise Settlement executed by the parties in the underlying civil case.

RULING

The Supreme Court dismissed the petition. The legal logic is grounded in the principle that a compromise agreement, once approved by the court, constitutes a final and executory judgment that terminates the litigation. A compromise is a contract whereby the parties, by making reciprocal concessions, avoid a litigation or put an end to one already commenced. Under the Civil Code, a compromise has the effect and authority of res judicata upon its court approval.
The records showed that the respondent judge had already rendered a final judgment approving the parties’ Compromise Settlement and ordering compliance with its terms. Consequently, the very subject matter of the certiorari petition—the proceedings before the lower court—was conclusively settled by this valid compromise judgment. Since the parties themselves voluntarily entered into the agreement to end their dispute, the supervening event of a final compromise judgment rendered the petition for certiorari moot and academic. There was no longer any live controversy or proceeding to be annulled or modified by the Supreme Court. The dismissal was therefore proper as the compromise extinguished the cause of action and the purpose of the certiorari proceeding.