Case Digest (G.R. No. 204447)
Facts:
The case involves Maria Magdalena V. Aromin, also known as Maria V. Aromin, as the petitioner against the heirs of spouses Wilfredo and Leonila Somis, namely Wilfredo A. Somis, Jr., Violita Somis-Flores, Eleanor Somis Flores, Olive Somis de Castro, Delia Somis-Soriano, Lalaine Somis-de la Cruz, Celso A. Somis, and all persons claiming rights under them, as respondents. The events leading to this case began in February 2007 when Maria instructed her son, Briccio V. Aromin, to pay the realty tax for three parcels of land owned by her and her deceased husband, Rufino Aromin. Upon payment, Briccio discovered that two of the parcels, specifically Lot A and Lot C, had been sold to the spouses Somis through a Deed of Sale with Right to Repurchase dated May 20, 1971, which Maria claimed she did not sign. Consequently, on June 18, 2007, Maria filed a Complaint for Annulment of Documents with Damages, asserting that the Deed of Sale was void due to her lack of signature.
On November...
Case Digest (G.R. No. 204447)
Facts:
Ownership of the Properties
Maria Magdalena V. Aromin (Maria) and her deceased husband, Rufino, owned three parcels of land:
- Lot A: PIN 008-08-037-03-002, ARP No. 037-00678 – a 2,827 sqm parcel of unirrigated riceland in Taberna, La Union.
- Lot B: PIN 008-08-005-08-025, ARP No. 005-01079 – a 1,228 sqm parcel of unirrigated riceland in Baccuit Sur, Bauang, La Union.
- Lot C: PIN 008-08-005-09-001, ARP No. 005-01018 – a 1,328 sqm parcel of land in Baccuit Sur, Bauang, La Union, with a 300 sqm house built on it.
Discovery of the Sale
In February 2007, Maria instructed her son, Briccio, to pay the realty taxes for the properties. Briccio discovered that Lots A and C had been sold to spouses Wilfredo and Leonila Somis (spouses Somis) through a Deed of Sale with the Right to Repurchase dated May 20, 1971, allegedly signed by Maria and Rufino.
Filing of the Complaint
On June 18, 2007, Maria filed a Complaint for Annulment of Documents with Damages, claiming she did not sign the Deed of Sale for Lot C, rendering it void. The spouses Somis were served summons and filed their Answer on August 30, 2007.
Compromise Agreement
On November 28, 2007, the parties entered into a Compromise Agreement, which stated:
- Lot A would belong to Maria.
- Lot B would belong to the spouses Somis.
The agreement was signed by Briccio (as Maria’s attorney-in-fact) and Celso Somis (as Leonila’s attorney-in-fact), with their respective legal counsels. The RTC approved the agreement in its January 17, 2008 Decision, which became final and executory.
Maria’s Motion to Amend the Agreement
On July 8, 2008, Maria filed a motion to set aside the writ of execution, claiming she intended to transfer Lot C (not Lot B) to the spouses Somis. The RTC granted her motion on October 20, 2008, ordering the correction of the PIN in the Compromise Agreement from Lot B to Lot C. The spouses Somis moved for reconsideration, which was denied.
Appeal to the Court of Appeals
The spouses Somis filed a Petition for Certiorari before the CA, which, in its January 22, 2010 Decision, ruled that the Compromise Agreement must be implemented strictly as written. The CA set aside the RTC’s October 20, 2008 Order, reinstating the January 17, 2008 Decision.
Maria’s Subsequent Motions
Maria filed a Motion to Annul the Compromise Agreement on February 15, 2010, but the RTC denied it on June 8, 2010, as the agreement had become final and executory. She then filed a Petition for Relief from Judgment, which was dismissed for non-payment of docket fees. Later, she filed a Petition for Annulment of Judgment before the CA, alleging:
- Lack of jurisdiction over Celso Somis, who allegedly had no authority to represent Leonila.
- The Compromise Agreement was void for lack of meeting of the minds.
- Extrinsic fraud due to her former counsel’s negligence.
The CA dismissed her petition on February 13, 2012, and denied her motion for reconsideration on November 12, 2012.
Issue:
- Whether the Compromise Agreement between the parties is valid and binding.
- Whether the CA erred in dismissing Maria’s Petition for Annulment of Judgment based on lack of jurisdiction and extrinsic fraud.
Ruling:
The Supreme Court denied Maria’s petition, affirming the CA’s Resolutions. The Court held:
- The Compromise Agreement is valid and binding. It was approved by the RTC in its January 17, 2008 Decision, which became final and executory. A compromise agreement, once approved by the court, has the force of res judicata and can no longer be disturbed.
- Maria’s claims of lack of jurisdiction and extrinsic fraud were unsubstantiated:
- Jurisdiction over the spouses Somis and Celso was properly acquired.
- Maria actively participated in the proceedings and was represented by counsel, negating her claim of extrinsic fraud.
- Alleged negligence of her former counsel does not constitute extrinsic fraud.
Ratio:
- (Unlock)