GR 79743; (November, 1989) (Digest)
G.R. No. 79743 November 6, 1989
MARIA PILAR MARQUEZ, petitioner, vs. HONORABLE COURT OF APPEALS, MARIA PAZ MARQUEZ, assisted by husband JOSE JO, LUZ JO MANAOIS, assisted by husband Lito Manaois, and Spouses ELISEO M. JO and DELMA DEL ROSARIO, respondents.
FACTS
The case originated from a dispute over the ownership of several parcels of land, primarily Lots 3428 and 4296, among the heirs of the late Eliseo F. Marquez. Petitioner Maria Pilar Marquez, Eliseo’s daughter from his first marriage, filed a complaint (Civil Case No. 4895) alleging that the subject lots were her exclusive inheritance from her mother, Rufina Velasco. She claimed her father, through fraud and breach of trust, had wrongfully registered portions of these lots in his own name and in the names of his children from his second marriage, including respondent Maria Paz Marquez. During pre-trial, the parties reached an agreement on the distribution of the contested properties, which the trial court approved.
The trial court subsequently rendered a decision based on this pre-trial agreement. Maria Paz Marquez moved for reconsideration and later for a new trial, which were denied. She then appealed to the Court of Appeals. The appellate court reversed the trial court’s decision, holding that the pre-trial agreement was not a valid compromise agreement as it lacked the signatures of the parties and their counsel, and remanded the case for further proceedings. Maria Pilar Marquez filed this petition for review.
ISSUE
Whether the Court of Appeals erred in setting aside the trial court’s final and executory decision, which was based on the parties’ pre-trial agreement, and in ordering a remand for further proceedings.
RULING
Yes. The Supreme Court granted the petition, annulled the Court of Appeals’ decision, and reinstated the trial court’s judgment. The legal logic is anchored on the doctrine of finality of judgments. The trial court’s decision, rendered on the basis of the stipulations and admissions made by the parties during the pre-trial conference, had long become final and executory. The Court emphasized that a judgment that has attained finality becomes immutable and unalterable.
The Court ruled that the agreement reached during the pre-trial and approved by the court was binding. The absence of signatures on a formal compromise document did not invalidate the binding judicial admissions made by the parties in open court, which were duly recorded. The trial court validly rendered its decision based on these stipulations. Consequently, the Court of Appeals had no authority to disturb this final judgment. Allowing such a remand would violate the fundamental principle that litigation must end, and would sanction endless litigation to the detriment of judicial administration. The Supreme Court reinstated the trial court’s decision to put a definitive end to the controversy.