Title
Gadrinab vs. Salamanca
Case
G.R. No. 194560
Decision Date
Jun 11, 2014
A dispute over a parcel of land in Manila between siblings and heirs of the late Spouses Talao leads to a ruling by the Supreme Court that judgments on compromise agreements are final and cannot be modified, reversing the decisions of the lower courts.
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Case Digest (G.R. No. 194560)

Facts:

  • The case "Gadrinab v. Salamanca" involves a land dispute at 2370 Nacar Street, San Andres, Sta. Ana, Manila.
  • The original owners were the late Spouses Nicolas and Aurelia Talao, who died intestate, leaving the property to their five children.
  • Respondents: Nora T. Salamanca, Antonio Talao, and Elena Lopez.
  • Petitioner: Nestor T. Gadrinab.
  • The siblings initially divided the property through an extrajudicial settlement, with Arsenia Talao later waiving her share in favor of her siblings.
  • Salamanca filed a complaint for partition against her siblings, including the heirs of the deceased Adoracion Talao, represented by Nestor and Francisco Gadrinab.
  • During mediation, a compromise agreement was reached and approved by the Regional Trial Court (RTC) of Manila on April 10, 2003, rendering it final and executory.
  • The agreement included provisions for the sale and appraisal of the property, distribution of rental income, and the vacating of the premises by Nestor Gadrinab.
  • Disputes arose regarding the execution of the agreement, leading Salamanca to file a motion for physical partition, which the RTC granted.
  • Nestor and Francisco Gadrinab appealed to the Court of Appeals (CA), which dismissed their appeal.
  • Nestor subsequently filed a petition for review with the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of Nestor T. Gadrinab, reversing and setting aside the decision of the Court of Appeals.
  • ...(Unlock)

Ratio:

  • A judgment on a compromise agreement is a judgment on the merits and has the effect of res judicata, making it final and executory unless set aside due to falsity or vices of consent.
  • The doctrine of immutability of judgments bars courts from modifying decisions that have attained finality.
  • The Court of Appeals erred in affirming the RTC's decision to allow physical partition, as it violated the principles of res judicata and immutability of judgments.
  • The parties had freely entered into the compromise agreement, and there was no evidence of fraud, mistake, or any vice of consent that woul...continue reading

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