G.R. No. 194560 - Gadrinab vs. Salamanca

The dispute involves siblings and heirs of the late Spouses Talao, who died intestate and left a parcel of land in Sta. Ana, Manila.
The Talao children originally divided the property through an extrajudicial settlement, with one sibling waiving her share in favor of the others.

During mediation in a complaint for partition filed in the Regional Trial Court (RTC) of Manila, the parties entered into a compromise agreement concerning both the subject land and rental proceeds from a duplex apartment unit on the property.
The agreement contained detailed stipulations including:

Sale of the subject property with proceeds to be divided equally among the parties.
An independent appraisal of the property by Cuervo Appraiser with the appraised value to be divided into four equal shares, and a specific provision that Mr. Antonio Talao would pay in advance the share of Francisco Gadrinab immediately after the appraisal report.
Distribution of the accumulated rental collection, which amounted to Php528,623.00, and any subsequently collected sum up to February 2003, equally among the parties on a set schedule.
A condition that, upon payment to Francisco Gadrinab, Mr. Nestor Gadrinab must vacate the premises within forty-five (45) days.
A mutual waiver of all claims and counter-claims arising from the case.
An agreed submission of the compromise agreement to the RTC for approval or issuance of a decision based thereon.

On April 10, 2003, the RTC approved the agreement, and by entry of judgment, the compromise agreement became final and executory, effecting res judicata on the merits.

Petitioner Nestor Gadrinab later filed a motion for execution of the compromise agreement to claim his one-fourth share of the accrued rental collection.
During the execution proceedings, the parties modified the division of rentals so that only three shares were recognized, as Nestor had been occupying one of the duplex units, with Antonio Talao undertaking to shoulder Nestor’s share.
Disagreements arose regarding the appraisal and interpretation of the agreement’s terms, with Antonio Talao contesting the validity of the initial appraisal and seeking a reappraisal, which was denied by the RTC.

Due to the ensuing non-compliance and discord among co-heirs regarding the execution of the compromise agreement, respondent Nora T. Salamanca filed a separate motion for physical partition of the property before the RTC.
On December 29, 2005, the RTC granted the motion for physical partition despite objections from petitioners Nestor and Francisco Gadrinab, who argued that the judgment on the compromise agreement had already acquired finality and should bar any such partition action.
The petitioners appealed the RTC ruling to the Court of Appeals, but the appellate court dismissed their appeal, reasoning that the persistent disagreements rendered the execution of the compromise agreement unjust and inequitable, which justified the physical partition as an enforcement measure.
Subsequently, on November 19, 2010, the Court of Appeals denied the petitioners’ motion for reconsideration, prompting the filing of the Rule 45 petition before the Supreme Court.

Petitioner Nestor Gadrinab contended that a judgment on a compromise agreement is a judgment on the merits, having res judicata effect and being immediately final and executory.
He argued that the RTC’s order granting physical partition effectively disturbed a final judgment, and that there was no substantiated agreement requiring his removal prior to sale.
Furthermore, petitioner claimed that his right to due process was violated by allowing a physical partition when a complete trial on partition would have enabled him to present evidence, such as his exclusive possession of part of the property.
Respondents, particularly Salamanca and Antonio Talao, maintained that the subsequent non-compliance with the compromise terms justified the physical partition as a remedial enforcement measure, emphasizing that any discrepancies did not alter the essential right of the parties over their shares.

Whether the physical partition of the property, ordered after the finality of the judgment on the compromise agreement, is valid and enforceable given that the compromise agreement had acquired res judicata effect.
Whether the doctrine of immutability of final judgments precludes modifying or disturbing a judgment on a compromise agreement, even if there are alleged non-compliance issues by some parties.
Whether the Court of Appeals erred in applying the exception for circumstances rendering execution unjust and inequitable, based solely on disputes arising after the final judgment.
Whether the petitioner’s right to due process was violated by enforcing a physical partition over the final and executory judgment that mandated the execution of the compromise agreement.