GR L 46330; (April, 1939) (Digest)
G.R. No. L-46330; April 22, 1939
IRENEO ABAD SANTOS and JOSE V. ABAD SANTOS, petitioners, vs. THE PROVINCE OF TARLAC, THE GOVERNMENT OF THE COMMONWEALTH OF THE PHILIPPINES, and DIEGO LOCSIN, Judge of First Instance of Tarlac, respondents.
FACTS
The Province of Tarlac filed an expropriation case to acquire lands for the Capas-Murcia diversion road. The petitioners (landowners) and the province entered into a compromise agreement on the land value, which the respondent judge approved in a partial decision. Five days later, the provincial fiscal moved for reconsideration, alleging he consented to the compromise under a mistaken belief that the provincial appraisal committee had approved the prices and that the province had lost its authority to expropriate because an executive order had declared the road a national highway under the Commonwealth government. The judge granted the motion, set aside his decision, reopened the case, and allowed the substitution of the Commonwealth as the plaintiff.
ISSUE
Whether the respondent judge acted without jurisdiction or with grave abuse of discretion in setting aside his partial decision based on a compromise agreement.
RULING
No. The petition for certiorari is denied. The partial decision had not become final because the motion for reconsideration was filed within the reglementary period. A trial court retains plenary control over its judgments before they become final and may modify or set them aside as law and justice require. A judgment based on a compromise stands on the same footing as an ordinary judgment and may be vacated on adequate grounds such as fraud, mistake, or absence of real consent. The sufficiency of the grounds alleged (mistake and lack of authority) involves an exercise of judgment, not jurisdiction. No abuse of discretion, defined as a capricious and whimsical exercise equivalent to lack of jurisdiction, was shown.
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