Case Summary (G.R. No. 213421)
Relevant Background and Procedural History
The case originated from a complaint filed by Carpio and Hardrock against Unirock for quieting of title, initially proceeding under Civil Case No. 94-3393 at the Regional Trial Court (RTC). Unirock was ultimately declared the rightful owner of the properties by the Supreme Court, with a final judgment entered on January 7, 2002. Following this, Unirock and Hardrock entered into a Memorandum of Agreement (MOA) allowing Hardrock the exclusive right to quarry the mineral resources, wherein royalties were to be paid to Unirock.
Events Leading to the Dispute
Subsequently, a separate complaint was filed by Teresa Gonzales against Unirock and Hardrock, seeking nullification of Unirock's title and claiming entitlement to the royalties. This ongoing litigation prompted Unirock to claim Hardrock's failure to pay the agreed royalties, which resulted in Unirock filing a motion for execution of the compromise agreement.
RTC and CA Rulings
The RTC denied Unirock's motion for execution in an order dated July 8, 2009, finding it premature due to Gonzales's pending complaint which raised questions about Unirock's title. The Court of Appeals (CA) later affirmed this ruling in a decision dated February 25, 2014, determining that Unirock's proof of royalty non-payment was insufficient and the execution would be unjust due to the ongoing issues regarding ownership.
Legal Principles and Court's Reasoning
The Supreme Court reiterated that a compromise judgment, once duly approved, has the status of a final and executory decision that typically cannot be disturbed unless there is a demonstration of vitiated consent or forgery. The Court underscored the principle of res judicata, emphasizing that any claims related to ownership from Gonzales do not affect the rights established under the prior final judgment in favor of Unirock concerning Hardrock's obligations.
Findings on Hardrock's Obligations
Although Hardrock had acknowledged Unirock's ownership in the MOA, the Supreme Court found that the previous rulings incorrectly conflated Gonzales's interests with Hardrock’s obligations. The Court conclu
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Case Overview
- Case Reference: G.R. No. 213421
- Date of Decision: August 24, 2020
- Court: Supreme Court of the Philippines
- Division: Second Division
- Petitioner: Unirock Corporation represented by Edison U. Ojerio
- Respondents: Armando C. Carpio and Hardrock Aggregates, Inc.
Procedural History
- The petition for review on certiorari challenges the Decision dated February 25, 2014 and the Resolution dated June 30, 2014 of the Court of Appeals (CA) in CA-G.R. CV No. 94051.
- The CA affirmed the Order dated July 8, 2009 of the Regional Trial Court (RTC) of Antipolo City, Rizal, Branch 73 (RTC-Br. 73), which denied Unirock's motion for issuance of a writ of execution for being premature.
Factual Background
- The case originated from a complaint for quieting of title filed by respondents against Unirock regarding properties titled under Unirock's name (Civil Case No. 94-3393).
- The Supreme Court ruled in favor of Unirock, establishing its ownership over the properties, with Entry of Judgment made on January 7, 2002.
- During execution proceedings, Unirock and Hardrock entered into a Memorandum of Agreement (MOA) allowing Hardrock to quarry mineral resources in exchange for royalties.
- The MOA was judicially approved on February 20, 2004, by RTC-Br. 73.
Subsequent Developments
- On March 14, 2006, Teresa Gonzales filed a complaint for nullification of title against Unirock and Hardrock, claiming ownership over the same properties.
- Gonzales