G.R. No. L-59690 October 28, 1987
LUIS HAGOSOJOS, petitioner, vs. HON. COURT OF APPEALS, and ARACELI H. VDA. DE HAGOSOJOS, et al., respondents.

FACTS

Anastacio Hagosojos contracted two marriages. With his first wife, Jacinta Jaucian, he had three children: petitioner Luis and respondents Araceli Alindogan and Lourdes Nicolas. After Jacinta’s death in 1959, but without the conjugal assets of the first marriage being partitioned, Anastacio married Araceli Hian in 1965, with whom he had three more children. In 1973, Anastacio donated a portion of the property from the first marriage’s conjugal assets, Lot No. 2736, to his minor son Henry from the second marriage. In 1974, Luis and his sisters filed a complaint for partition against Anastacio. After Anastacio’s death, the parties entered into a Compromise Agreement, which was approved by the trial court in a December 5, 1975 decision. The agreement awarded the entire property, including Lot No. 2736, to the children of the first marriage.
After the judgment became final, the widow and children from the second marriage filed a motion to amend the decision, alleging that the Compromise Agreement was vitiated by mistake because they had signed it unaware that Lot No. 2736 had already been donated to Henry and was thus excluded. The trial court denied the motion, ruling it had no authority to amend a final judgment based on a compromise. The Court of Appeals reversed, setting aside the compromise agreement on the ground of mistake.

ISSUE

Whether the Court of Appeals erred in setting aside the final and executory judgment based on the Compromise Agreement on the ground of mistake.

RULING

Yes. The Supreme Court reinstated the trial court’s decision. A judicial compromise, once approved by final judgment, has the force of res judicata and is immediately executory. It can no longer be set aside except upon a clear showing of vitiation of consent, such as forgery, fraud, misrepresentation, or coercion. The alleged “mistake” in this case was a mistake of law or an error of judgment, not a vitiating mistake. The respondents, particularly the widow Araceli who was assisted by counsel, were presumed to know the law and the consequences of their agreement. Their claim of not knowing the donation’s legal implications does not constitute the factual or material mistake required to nullify consent. Furthermore, the validity of the donation itself was questionable, as it involved a property still part of the unpartitioned conjugal assets of the first marriage, wherein Anastacio’s ownership was merely ideal or undivided. The Supreme Court found no compelling reason to disturb the finality of the compromise judgment.