Facts:

The case involves two families headed by respondents and defendants, Faustino Samonte and Lourdes Manuel, and plaintiffs Arturo and Francisco Samonte, along with various affiliated parties, all of whom are children from Faustino Samonte’s first marriage to Bernardina Rodriguez. The events leading to the legal dispute began when Faustino Samonte and Bernardina acquired three parcels of unregistered land and a residential house during their marriage. Following Bernardina's death in February 1935, Faustino continued to manage the property and its income for the benefit of his children and himself. He also ventured into leases of fishponds in Bulacan, which were supported by borrowed capital and the income derived from their properties.

In a complaint filed against Faustino Samonte and Lourdes Manuel, plaintiffs Arturo and Francisco claimed that Faustino entered into a second marriage with Lourdes without properly liquidating the properties and income from his first marriage. T

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Facts:

Parties and Family Relationships

• Plaintiffs: Arturo Samonte, Francisco Samonte, and Deogracias Samonte, who are children of defendant Faustino Samonte by his first marriage to Bernardina Rodriguez (now deceased).
• Defendants:
• Faustino Samonte, who married twice – first to Bernardina Rodriguez and later to Lourdes Manuel.
• Other children of Faustino from his first marriage include Ricardo, Cayetano, and Raul Samonte.
• Raul Samonte, during his lifetime, married and begot Jaime Samonte.
• Lourdes Samonte, daughter of Faustino, married Alejandro Villanueva and had children named Cipriano, Ernesto, and Teresita (all surnamed Villanueva).

Background of the Conjugal Partnership and Property

• During Faustino Samonte’s first marriage with Bernardina Rodriguez, they acquired conjugal properties:
• Three (3) parcels of unregistered land (as described in the complaint).
• A residential house.
• After Bernardina Rodriguez’s death in February 1935, Faustino continued to hold and manage these properties along with an additional parcel in Bambang, Bulacan, for the benefit of his children and himself.

Business Ventures and Leased Fishponds

• With the income from the properties and a borrowed capital secured by them, Faustino, with help from his sons and son-in-law, entered into long-term leases of first-class fishponds in Bulacan.
• The fishponds included several under distinct names such as:
• “Kay Bituin”
• “Kay Sombrero”
• “Kay Gogue”
• “Kay Katwiran”
• “Kay Katig”
• “Kay Tubong”

Claims and Relief Sought by the Plaintiffs

• Plaintiffs alleged that:
• Defendant Faustino Samonte contracted his second marriage with Lourdes Manuel without liquidating or partitioning the conjugal properties of his first marriage.
• He used the rights, interests, and participation of his children from his first marriage as capital in the conjugal partnership with his second wife.
• Plaintiffs demanded that:
• All properties brought from the first marriage and the income derived from the leased fishponds be divided between them and the conjugal partnership of Faustino and Lourdes Manuel.
• Defendants be ordered to render a complete accounting of the fruits and income from these properties, and pay attorney’s fees of P20,000.00.
• Plaintiffs further sought a writ of preliminary injunction restraining the defendant-spouses from gathering or harvesting the products from the properties and fishponds pending the appointment of a receiver.

Pleadings and Counterclaims

• On June 30, 1967, defendant-spouses Faustino Samonte and Lourdes Manuel filed their answer:
• They admitted some allegations and denied others.
• They argued that prior to the complaint, Faustino had been willing to partition the properties.
• They asserted that the plaintiffs had no participation in the properties acquired during the second marriage.
• They counterclaimed for moral damages and attorney’s fees.
• On August 8, 1967, other defendants (including Cayetano Samonte, Alejandro Villanueva, Cipriano Villanueva, Ernesto Villanueva, Teresita Villanueva, Jaime Samonte, and Juliana Vda. de Samonte) filed their answer denying the material allegations and cross-claimed against Faustino and Lourdes Manuel, asserting a partnership over the leased fishponds.
• A business arrangement had been agreed upon regarding the leased fishponds, with roles assigned (e.g., Raul Samonte as manager initially, succeeded later by Cayetano Samonte).

The Compromise Agreement and Subsequent Court Proceedings

• On September 15, 1967, a comprehensive compromise agreement was executed by several parties:
• It provided that defendants (Faustino Samonte, Lourdes Manuel, Cayetano Samonte, Ricardo Samonte, Romeo Samonte, Jaime Samonte, Cipriano Villanueva, and Ernesto Villanueva) would pay the plaintiffs a total sum of P40,000.00 in settlement.
• Plaintiffs Arturo, Francisco, and Deogracias Samonte, along with Romeo Samonte and Consolacion Donato, waived any claims to accounting and partition of the properties.
• The parties also stipulated terms regarding the partnership over the leased fishponds, notably the allocation of specific fishponds (e.g., “Kay Katwiran” and “Kay Sombrero” to certain defendants; “Kay Katig” to Faustino and Lourdes Manuel exclusively) and the sharing of improvement expenses.
• The partnership was declared terminated upon execution of the agreement.
• On September 19, 1967, the lower court approved the compromise agreement and ordered strict compliance.
• Subsequent Motions and Appeals:
• On March 14, 1968, defendants Cayetano Samonte, et al. filed a motion to suspend the compromise agreement alleging misrepresentation regarding the lease expiration date of “Kay Katwiran” (expected to expire in 1972 but actually expiring in 1970).
• The lower court denied this motion on March 25, 1968.
• On April 10, 1968, the same defendants filed a motion to set aside the judgment approving the compromise agreement, contending that they had not received notice of the judgment in time.
• Defendant-spouses opposed this motion, citing that it was filed beyond both the 6‑month and 60‑day periods as prescribed under the Rules of Court.
• After exchanges and an order denying the motion to set aside, the defendants-appellants (Cayetano Samonte, et al.) appealed to the Court of Appeals, which then certified the case to the Supreme Court on purely questions of law.

Issue:

Whether the lower court committed an error by denying the motion to set aside the judgment based on the compromise agreement.

• Specifically, the principal issue is the timeliness of the motion filed by defendants-appellants (Cayetano Samonte, et al.) under the provisions of Section 3, Rule 38 of the Rules of Court.
• Whether notice for purposes of reckoning the filing period should be the receipt by counsel or the actual entry/issuance of the judgment.

Whether the alleged fraud in the representations regarding the lease of the fishpond “Kay Katwiran” can be considered sufficient grounds to set aside a final and executory judgment based on a compromise agreement.

• The issue includes determining if the alleged misrepresentation was used to procure the judgment or merely pertains to the underlying cause of action.
• Whether defendants-appellants’ failure to file the motion within the prescribed 60-day period after learning of the judgment, and within six (6) months after the judgment’s entry, precludes them from obtaining relief under Rule 38—even if they raised issues of fraud.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)