G.R. No. 130864 - Harold vs. Aliba

In January 1993, petitioner Maria L. Harold engaged respondent Agapito T. Aliba, a geodetic engineer, to conduct a relocation survey and to execute a consolidation-subdivision of properties. This project involved not only Harold’s property but also that of her sister, Alice Laruan, located in Pico, La Trinidad, Benguet.
After the completion of his work, Aliba received a payment of ₱4,050 from Harold. Despite repeated demands for the return of the certificates of title to the properties, Aliba delayed their return for more than one year.

Around January 1994, Aliba persuaded Harold and her husband to sign a document purportedly necessary to facilitate both the consolidation-subdivision and the issuance of separate transfer certificates of title.
Both Harold and her husband signed the document without reading its contents. Subsequently, on April 18, 1994, a truck loaded with construction materials arrived at Harold’s lot, and it was discovered that Aliba had sold the lot to a third party.

Following the discovery of the sale, Aliba made several offers to Harold to settle the dispute by offering money. Initially, the offer was ₱400,000, later increased to ₱500,000 as purchase price for the lot.
On May 3, 1994, Harold agreed to accept ₱500,000 as partial payment, noting that the fair market value of the lot was pegged at ₱1,338,000 (calculated at ₱6,000 per square meter).
On the same day, Harold was coerced into signing an acknowledgment receipt along with other papers that misleadingly indicated she had accepted ₱480,000 as full and final payment for the lot.

Harold later discovered that Aliba had manipulated the records in such a way that it appeared she had sold the lot to him for ₱80,000. This fraudulent deed of sale resulted in the cancellation of the original certificates of title, which were then transferred to Aliba.
Realizing the impropriety, Harold sought the fair market value of her property but received no cooperative response from Aliba.

The dispute was referred to local dispute resolution mechanisms, specifically to Punong Barangay Limson Ogas and the Lupong Tagapamayapa.
On June 8, 1994, during barangay conciliation proceedings, the parties agreed that Aliba would pay an additional ₱75,000 to the initial ₱500,000 already paid to Harold, thereby settling their dispute amicably.
Aliba tendered ₱70,000, which Harold accepted, with the transaction evidenced by an acknowledgment receipt signed by both parties, attested by the Lupon chairman and several barangay officials.
According to the minutes, the remaining balance of ₱5,000 was scheduled to be paid on the following day, June 9, 1994. However, when Aliba returned with ₱5,000 that afternoon, Harold refused to accept the amount, claiming it was insufficient.

As a result of her refusal to accept the remaining ₱5,000 and presumably wanting to pursue the full recovery of what she believed she was owed, Harold opted to elevate the matter to the courts.
A certification to file action was issued by the Office of the Lupong Tagapamayapa on June 29, 1994, and Harold filed a complaint against Aliba before the Municipal Trial Court (MTC) of La Trinidad, Benguet.
In his Answer, Aliba moved for the dismissal of the complaint, arguing that he had been absolutely released from any further obligation through the amicable settlement.
On September 4, 1995, the MTC issued an Order dismissing Harold’s complaint, holding that there was a valid and mutually acceptable settlement as evidenced by the barangay proceedings.
Harold’s appeal was affirmed by the Regional Trial Court on February 20, 1996, and subsequently, the Court of Appeals affirmed the dismissal in the decision dated September 3, 1997.

Harold contended that the amicable settlement was flawed because there was no true meeting of the minds between the parties regarding the matter at issue.
She also questioned whether the acknowledgment receipt and the minutes of the proceedings substantially complied with the requirements of Section 411 of Republic Act No. 7160 (the Local Government Code of 1991).
Another ground raised was that her act of not receiving the remaining balance and insisting on court intervention should not be construed as a repudiation of the amicable settlement.

Whether the dismissal of the complaint by the lower courts was correct on the sole ground that the parties had reached a mutually acceptable amicable settlement during the barangay conciliation proceedings, notwithstanding Harold’s contention that there was no meeting of the minds regarding the subject matter.

Whether the acknowledgment receipt and the minutes of the barangay conciliation proceedings, despite not being presented as a formal "Amicable Settlement" document, substantially complied with the requirements of Section 411 of RA 7160.

Whether Harold’s refusal to accept the remaining balance of ₱5,000 should be considered a repudiation of the amicable settlement, thereby justifying the filing of a formal complaint, or if such conduct merely demonstrates her desire to acquire additional benefit beyond the mutually agreed compromise.