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 Summary (G.R. No. 204447)

Origins of the Dispute and the Parties’ Instrumented Settlement

Petitioner alleged that she and her deceased husband Rufino owned three parcels of land in Bauang and Taberna, La Union, identified by specific PINs and ARP classifications: Lot A (PIN 008-08-037-03-002), Lot B (PIN 008-08-005-08-025), and Lot C (PIN 008-08-005-09-001, with a 300-square-meter house). She claimed that she had instructed her son, Briccio V. Aromin, to pay realty tax, and that Briccio later 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 petitioner and Rufino.

Petitioner then filed a complaint for annulment of documents with damages on June 18, 2007, asserting that she did not sign the deed of sale transferring Lot C to the spouses Somis, and therefore the sale was void. Summons were served and answered by the spouses Somis on August 30, 2007. After pleadings and before final adjudication, the parties executed a Compromise Agreement on November 28, 2007. That compromise provided, as consideration for withdrawing petitioner’s case against Leonila Somis, that Lot A covered by PIN No. 008-08-037-03-002 would belong to petitioner, while Lot B covered by PIN No. 008-08-005-08-025 would belong to the Somis. The compromise was signed by Briccio V. Aromin as petitioner’s attorney-in-fact and Celso Somis as Leonila’s attorney-in-fact, with counsel assisting.

RTC Approval, Finality, and the Execution Phase

The RTC approved the compromise in a January 17, 2008 Decision. The decision became final, and a Writ of Execution was issued on June 27, 2008. Following issuance of the writ, on July 8, 2008, petitioner filed a motion to set aside the order granting the writ of execution. She asserted that her intention was to give Lot C (not Lot B) to the spouses Somis and claimed that the compromise had an erroneous property description or PIN.

In an October 20, 2008 Order, the RTC granted petitioner’s motion and ordered that the PIN 008-08-005-08-025 (Lot B as written in the compromise) be changed to 008-08-005-09-001 (Lot C). The spouses Somis sought relief, and the Court of Appeals granted their petition for certiorari in CA-G.R. SP No. 109076, holding that once a court-approved compromise agreement became a final and executory judgment, it had to be implemented strictly according to its terms unless it was set aside through available legal remedies. As a result, the RTC’s October 20, 2008 Order was set aside and the January 17, 2008 Decision was reinstated.

Post-Approval Motions and Petitioner’s Attempts at Reopening

On February 15, 2010, petitioner, through counsel Atty. Benilda Indasen, filed a Motion to Annul the Compromise Agreement, which the RTC denied in a June 8, 2010 Order, reasoning that the compromise agreement had already become final and executory in light of the Court of Appeals’ January 22, 2010 Decision in CA-G.R. SP No. 109076. On July 13, 2010, petitioner filed a Petition for Relief from Judgment assailing the RTC’s January 17, 2008 Decision; however, it was dismissed for non-payment of docket fees.

Petitioner later engaged Atty. Manolito S. Hidalgo, who filed a petition for reformation of the compromise agreement. That petition was withdrawn when petitioner chose to file, instead, the Petition for Annulment of Judgment before the Court of Appeals in CA-G.R. SP No. 123064.

The Court of Appeals’ Disposition and the Narrow Grounds for Annulment of Judgment

Before the Court of Appeals, petitioner contended that the RTC lacked jurisdiction because: first, Celso Somis allegedly was not authorized to represent Leonila in the compromise agreement; and second, the subject matter was allegedly beyond the court’s authority because the compromise agreement was purportedly void under Article 1318 of the Civil Code for failure to comply with essential contractual requisites. Petitioner also alleged that the RTC’s January 17, 2008 Decision was obtained through extrinsic fraud, asserting that her former counsel Atty. Indasen connived with the mediator and Somis’s counsel to have Lot B assigned to the Somis by writing an incorrect PIN. She further blamed Atty. Indasen’s alleged gross negligence.

The Court of Appeals, in its February 13, 2012 Resolution, dismissed the petition. It emphasized that under Section 2, Rule 47, a judgment could be annulled only on the twin grounds of extrinsic fraud and lack of jurisdiction. It found no basis to conclude that the RTC lacked jurisdiction and held that the extrinsic-fraud claim lacked credibility. The appellate court underscored that the “overriding consideration” in alleged extrinsic fraud was whether a fraudulent scheme by the prevailing litigant prevented the losing party from having a day in court. It ruled that petitioner was not deprived of due process, because she actively participated and was properly represented during the trial court proceedings. It later denied reconsideration in its November 12, 2012 Resolution.

Issues Framed on Appeal: Validity of the Compromise and Finality of the RTC Decision

On review, petitioner maintained that both the November 28, 2007 Compromise Agreement and the January 17, 2008 RTC Decision should be declared void. She anchored the alleged invalidity on the claimed absence of Celso’s authority to represent Leonila, on the supposed lack of a true meeting of minds because she intended to transfer Lot C rather than Lot B, and on the assertion that extrinsic fraud and her then counsel’s negligence deprived her of her property.

The Court denied the petition.

The Supreme Court’s Reasoning on Finality, Meeting of Minds, and Binding Effect

The Supreme Court reiterated that when a decision becomes final and executory, it becomes valid and binding upon the parties and their successors in interest, and it can no longer be disturbed or reopened even if it is believed to be erroneous. It stressed that a final judgment acquires immutability, and that the orderly administration of justice requires that judicial disputes reach a legally fixed point of finality. The Court held that the compromise agreement, having been approved by the RTC in the January 17, 2008 Decision and having become final, could not be undone except through the legally available remedies—remedies petitioner failed to successfully invoke.

The Court further held that the appellate court had already addressed and disposed of petitioner’s claims in the prior certiorari proceeding under CA-G.R. SP No. 109076, which reinstated the RTC’s approval of the compromise and rejected the RTC’s later attempt to alter the PIN description. In that setting, the final and executory character of the RTC decision made the compromise agreement binding among the parties.

On contract formation, the Court applied Article 1305 and Article 1318. A contract, it explained, exists as a meeting of minds where one binds to give or to render some service, and it requires (1) consent, (2) object certain, and (3) cause of the obligation. The Court held that the compromise agreement was clear: it reflected mutual agreement to transfer the specified properties. Even acknowledging that petitioner’s counsel prepared the written instrument, the Court reasoned that the petitioner or her representative was expected to exercise due diligence in reviewing the entries before signing. The Court also noted that if petitioner believed there was a mistake in the property to be transferred, she should have pursued available remedies immediately after discovering the alleged error.

The Court found it significant that petitioner moved to set aside execution only on July 8, 2008, after the RTC decision had immediately become final and executory and after the writ of execution had been issued in June 27, 2008. It also sustained the appellate court’s denial of annulment since petitioner’s theory did not fit within the limited grounds for annulment under Section 2, Rule 47.

Jurisdiction, Due Process, and the Court’s Treatment of Extrinsic Fraud

As to jurisdiction, the Court recognized that jurisdiction over the parties in a civil action is acquired upon filing of the complaint for the plaintiff, and over a defendant upon valid service of summons or the defendant’s voluntary appearance. It held that summons were duly served on the spouses Somis, and that jurisdiction over them was therefore properly acquired. With respect to Celso, the Court held that jurisdiction over his person was also acquired when he voluntarily appeared in the proceeding by signing and filing the compromise agreement.

The Court rejected petitioner’s argument that Celso lacked authority to represent Leonila. It noted that this alleged lack of authority was effectively affirmed by Celso’s subsequent act of filing a petition for certiorari in CA-G.R. SP No. 109076 to uphold the accuracy of the contents in the compromise agreement. The Court also held that jurisdiction over the subject matter comes from the Constitution or the law, and it affirmed that the RTC had authority to hear petitioner’s complaint, which sought annulment of a contract and reconveyance, an action the Court characterized as incapable of pecuniary estimation and thus within the RTC’s jurisdiction.

On alleged extrinsic fraud, the Court held that petitioner was not denied due process. It explained extrinsic fraud as fraud committed outside the trial that prevents the defeated party from fully presenting the case, such as by keeping a party away from court, inducing a false compromise, keeping the defendant in ignorance of the suit, or through an attorney’s fraudulent or unauthorized connivance at the party’s defeat. The Court emphasized that petitioner actively participated and was properly assisted by counsel both in the RTC and the appellate court.

The Court recalled petitioner’s procedural attempts after discovering the perceived error: the initial motion to amend was granted by the RTC in October 20

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