Case Summary (G.R. No. 259469)
Factual Background
The Spouses Sacramento owned parcels of land in Barangay Sto. Niño, Tacloban City, specifically Lot No. 4144. The City Government of Tacloban sought to acquire a portion of Lot No. 4144 for use as an access road to the city’s dumpsite. On September 8, 2008, the parties entered into a Compromise Agreement which stipulated the payment of compensation for the land and included provisions for the dismissal of the case with prejudice. The RTC approved the Compromise Agreement on September 18, 2008, and it was ratified by the Sangguniang Panlungsod on September 24, 2008.
Withdrawal of Ratification
However, on November 19, 2008, the Sangguniang Panlungsod issued a resolution withdrawing its ratification of the Compromise Agreement, rendering it null and void. The Spouses Sacramento then moved for the enforcement of the agreement, which the RTC initially denied due to the withdrawal of ratification. Following a motion for reconsideration, the RTC ordered enforcement of the Compromise Agreement on June 4, 2009, resulting in the issuance of a Writ of Execution on July 1, 2009.
Legal Proceedings and Rulings
The City Government of Tacloban challenged the RTC's enforcement of the Compromise Agreement through a petition for certiorari (CA-G.R. SP No. 04526), but the Court of Appeals dismissed the petition, affirming the validity of the Writ of Execution. The decision declared that a compromise agreement, once judicially approved, is immediately executory and has the effect of res judicata.
Subsequent Attempts to Quash the Writ
The City Government of Tacloban later attempted to quash the Writ of Execution and lift related notices of attachment but faced further opposition when the RTC continued to enforce the writ. A new petition for review on certiorari was filed as CA-G.R. SP No. 07675, where the City Government contested Judge Lilagan’s implementation of the Writ of Execution, which had previously been quashed.
Court of Appeals' Decision
On April 30, 2015, the Court of Appeals dismissed the second petition based on the doctrine of res judicata, indicating overlapping issues and parties concerning the prior case (CA-G.R. SP No. 04526). The court emphasized that all necessary elements for res judicata were present, given that both cases involved the same parties and similar subjects.
Supreme Court Ruling
Upon appeal, the Supreme Court found the petition unmeritorious, upholding the application of the compromise agreement under the principles of res judicata. The Court reiterated that the compromise agreement, once approved judicially, becomes binding and executory, thus the City Government could not evade compliance due to changed positions by the city council.
Legal Principles Applied
The case elucidated several
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Overview of the Case
- The case revolves around a Petition for Review on Certiorari filed by the City Government of Tacloban against the Court of Appeals and other respondents, challenging a decision regarding the enforcement of a compromise agreement related to an eminent domain case.
- The importance of the doctrine of res judicata is emphasized, which seeks to prevent the relitigation of settled issues, thereby maintaining judicial efficiency.
Antecedents
- The Spouses Esteban R. Sacramento and Salvacion Siony L. Sacramento owned a parcel of land, including Lot No. 4144, located in Barangay Sto. Niño, Tacloban City.
- The City Government of Tacloban initiated a complaint for eminent domain for a portion of Lot No. 4144 for access to a dumpsite.
- A Compromise Agreement was entered into on September 8, 2008, stipulating compensation of ₱280 per square meter for approximately 49,057 square meters, totaling ₱13,735,960, with specific payment schedules outlined.
- The agreement included terms regarding tax obligations, dismissal of the case, mutual release of claims, and a declaration of ownership, with a provision for enforcement in case of material breach.
Court Approval and Ratification
- The Regional Trial Court (RTC), presided by Judge Rogelio C. Sescon, approved the Compromise Agreement on September 18, 2008.
- The Sangguniang Panlungsod ratified the agreement on September 24, 2008, through Resolution No. 2008-10-530.
- On November 19, 2008, the Sangguniang Panlungsod withdrew its ratifica