G.R. No. L-38314 June 25, 1974
BELEN S. RODRIGUEZ and JOSE S. SANTOS, JR., petitioners, vs. HON. FEDERICO ALIKPALA (Presiding Judge, Branch XXII, Court of First Instance of Manila), FEDERICO TOLENTINO and FELISA TOLENTINO, respondents.

FACTS

Petitioner Belen S. Rodriguez filed a collection suit against spouses Manuel and Fe Rebollado before the Manila City Court. A writ of preliminary attachment was issued. Fe Rebollado pleaded for time, leading to an agreement where her parents, respondents Federico and Felisa Tolentino, would bind themselves jointly and severally with the Rebollados to pay the obligation. A motion for judgment on a compromise embodying this agreement was submitted to and approved by the city court. The judgment’s dispositive portion approved the compromise and enjoined strict compliance by the parties but did not explicitly reiterate the Tolentinos’ payment obligation from the agreement’s body.
The Rebollados defaulted. Rodriguez secured a writ of execution from the city court against both the Rebollados and the Tolentinos. The Tolentinos then filed a certiorari action in the Court of First Instance (CFI) to enjoin execution against them. The CFI granted the petition, ruling the judgment could not be executed against the Tolentinos because its dispositive portion did not explicitly order them to pay and because the city court never acquired jurisdiction over their persons.

ISSUE

Whether the Court of First Instance erred in excluding the Tolentino spouses from the effects of the writ of execution issued pursuant to the judgment on a compromise.

RULING

Yes, the CFI erred. The Supreme Court reversed its decision. On the first ground, a judgment based on a compromise need not have its dispositive portion reiterate every obligation detailed in the agreement’s body. The approval of the compromise and the order for strict compliance incorporate the entire agreement’s terms for execution purposes. The form used was valid and sufficient for execution against all obligors named in the compromise.
On the second ground, the Tolentinos voluntarily submitted to the city court’s jurisdiction. They willingly signed the compromise agreement to assist their daughter. By joining the motion for judgment on that compromise and assuming unequivocal joint and several liability within its terms, they effectively appeared before the court and submitted to its authority. A person who voluntarily participates in a proceeding and assumes an interest in its adjudication cannot later deny the court’s jurisdiction over them. The principle of estoppel applies, and equity recognizes jurisdiction acquired through such voluntary appearance and assumption of liability. Consequently, the Tolentinos are bound by the judgment and subject to the writ of execution. The order of the city court for execution against them was affirmed.