Title
Aromin vs. Heirs of Somis
Case
G.R. No. 204447
Decision Date
May 3, 2021
Maria Aromin contested a Compromise Agreement over disputed land sales, alleging fraud and lack of jurisdiction. Courts upheld the agreement as final and binding, dismissing her claims for insufficient evidence.
A

Case Digest (G.R. No. 106063)

Facts:

  • Parties and properties involved in the underlying dispute
  • Petitioner Maria Magdalena Aromin (also known as Maria V. Aromin) owned with her deceased husband Rufino three parcels of land.
  • The parcels were identified as follows:
1) Lot A: PIN 008-08-037-03-002, ARP No. 037-00678, an irrigated riceland in Taberna, La Union, with an area of 2,827 square meters. 2) Lot B: PIN 008-08-005-08-025, ARP No. 005-01079, an unirrigated riceland in Baccuit Sur, Bauang, La Union, with an area of 1,228 square meters. 3) Lot C: PIN 008-08-005-09-001, ARP No. 005-01018, a 1,328 square meter parcel in Baccuit Sur, Bauang, La Union, with a 300 square meter house built within the property.
  • Respondents were 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.
  • The deed of sale and Maria’s allegation of invalidity
  • In February 2007, Maria instructed her son Briccio V. Aromin to pay realty tax for the lots.
  • Briccio discovered that Lots A and C were sold to the spouses Wilfredo and Leonila Somis through a Deed of Sale with the Right to Repurchase dated May 20, 1971, allegedly signed by Maria and Rufino.
  • Maria alleged that she did not sign the deed of sale transferring Lot C to the spouses Somis, hence it was void.
  • Maria’s complaint and the subsequent compromise agreement
  • On June 18, 2007, Maria filed a Complaint for Annulment of Documents with Damages in which she asserted that she did not sign the deed of sale transferring Lot C to the spouses Somis.
  • Summons were served on the Somises, and they filed their Answer on August 30, 2007.
  • On November 28, 2007, the parties entered into a Compromise Agreement providing, in substance, for property swapping based on withdrawal of the case:
1) Maria would withdraw her case against Leonila. 2) The spouses agreed that the property covered by PIN No. 008-08-037-03-002 (Lot A) would belong to Maria. 3) In turn, Maria agreed that the property covered by PIN No. 008-08-005-08-025 (Lot B) would belong to Leonila (through the spouses Somis).
  • The Compromise Agreement was signed with:
1) Briccio V. Aromin as First Party’s attorney-in-fact for Maria. 2) Celso Somis as Second Party’s attorney-in-fact for Leonila. 3) Counsel for both sides, including Atty. Benilda E. Indasen for the First Party.
  • The trial court approved the Compromise Agreement in a January 17, 2008 Decision, which became final.
  • A Writ of Execution issued on June 27, 2008.
  • Events after execution and the RTC orders
  • On July 8, 2008, Maria filed a motion to set aside the order granting the issuance of the writ of execution.
  • Maria claimed she intended to give Lot C (not Lot B) to the spouses Somis.
  • She asserted that the description or PIN of the property given to the spouses Somis under the Compromise Agreement was erroneous.
  • In its October 20, 2008 Order, the RTC granted the motion and directed that the PIN in the Compromise Agreement be changed from PIN 008-08-005-08-025 (Lot B) to PIN 008-08-005-09-001 (Lot C).
  • The spouses Somis moved for reconsideration, but the RTC denied it.
  • Appellate court intervention and reinstatement of the compromise terms
  • The spouses Somis filed a Petition for Certiorari in the appellate court, docketed as CA-G.R. SP No. 109076.
  • In a January 22, 2010 Decision, the CA granted the petition and ruled that unless the court-approved compromise agreement was set aside through available legal remedies, it had the nature of a final and executory judgment that must be implemented strictly according to its terms.
  • As a result, the RTC’s October 20, 2008 Order was set aside.
  • The effect was the reinstatement of the RTC’s January 17, 2008 Decision approving the compromise.
  • Maria’s subsequent attempts to annul and reform the compromise
  • On February 15, 2010, Maria, through counsel Atty. Benilda Indasen, filed a Motion to Annul the Compromise Agreement.
  • In a June 8, 2010 Order, the RTC denied the motion as moot and academic, reasoning that the Compromise Agreement had become final and executory in light of the CA’s January 22, 2010 Decision.
  • On July 13, 2010, Maria filed a Petition for Relief from Judgment assailing the RTC’s January 17, 2008 Decision that approved the compromise and enjoined strict compliance.
  • The petition for relief was dismissed for non-payment of docket fees.
  • Maria later engaged Atty. Manolito S. Hidalgo, who filed a Petition for Reformation of Compromise Agreement.
  • The reformation petition was withdrawn when Maria opted to file the instant petition for Annulment of Judgment before the CA.
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Issues:

  • Whether the court-approved Compromise Agreement and the RTC Decision approving it could be annulled on the grounds invoked by Maria
  • Whether the RTC acquired jurisdiction over Celso and/or Leonila and over the subject matter.
  • Whether the Compromise Agreement was void for alleged failure to comply with the requisites for a valid contract under Art. 1318 of the Civil Code, due to absence of meeting of the minds as to the property intended (Lot C versus Lot B).
  • Whether the January 17, 2008 Decision approvin...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)
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