G.R. No. L-17333 December 29, 1962
JULIANA ABAD and SINAI C. HAMADA, plaintiffs-appellees, vs. BLAS SAN JUAN, defendant-appellant.

FACTS

In Civil Case No. 288, Blas San Juan and Juliana Abad, claiming to be the son and widow, respectively, of the late Vicente San Juan, sued to enforce rights over a portion of Lot No. 117-B allegedly purchased by Vicente from Sioco Cariño. The parties eventually entered into a compromise agreement, which was approved by the Court of First Instance of Baguio in a decision dated May 4, 1954. The agreement stipulated that the northern half of Block 1 of the lot would be adjudicated equally to Juliana Abad and Blas San Juan as heirs of Vicente San Juan. This decision became final and executory.
Subsequently, Blas San Juan refused to comply with the terms of the compromise by agreeing to a physical partition of the property. Juliana Abad, joined by Sinai C. Hamada (who had an interest in the segregation), filed the present action for partition to enforce the prior final judgment. In his defense, Blas San Juan argued that the compromise was vitiated by fraud, claiming he possessed documents proving the land was never owned by Sioco Cariño and that Juliana Abad was never married to his father.

ISSUE

Whether the trial court erred in ordering the partition of the property based on the final and executory compromise judgment, despite the appellant’s claim of fraud in the execution of that compromise.

RULING

The Supreme Court affirmed the trial court’s decision ordering partition. The legal logic rests on the finality and immutability of judgments. The compromise agreement in Civil Case No. 288 was voluntarily entered into by the parties and their counsel, and it was judicially approved. The Court emphasized that the Court of First Instance had jurisdiction over the subject matter, the parties, and the res. Consequently, the resulting decision was valid and binding, regardless of any alleged error.
The appellant’s claim of fraud pertained to Juliana Abad’s status as a widow, which he argued nullified the compromise under Article 2035 of the Civil Code (compromises upon questions of civil status). The Court ruled this provision inapplicable because the principal issue in the original case was not the marital status of Juliana Abad but the ownership and possession of the land based on an alleged sale. Her status was not the subject matter of the compromise but was a factual allegation admitted by the defendants in their pleadings and reiterated in the agreement itself.
At most, the alleged fraud would have rendered the prior decision merely voidable, not void. A voidable judgment must be challenged through a timely appeal or a direct action to annul it. No appeal was taken from the 1954 decision, and it became final and executory. The appellant failed to substantiate his claim of fraud in the present proceedings. Therefore, the lower court correctly issued an order for partition to execute the final judgment, which had conclusively settled the rights of the parties. The award of attorney’s fees was also upheld.