Hagosojos v. Court of Appeals
REITERATIONFacts
The Antecedents: Anastacio Hagosojos contracted two marriages. His first marriage produced three children, including petitioner Luis Hagosojos. His second marriage produced three other children. Anastacio donated Lot No. 2736, a portion of the conjugal partnership assets of the first marriage, to his minor son Henry Hagosojos, born from the second marriage. Luis Hagosojos and his full sisters filed a complaint for partition of the conjugal assets of the first marriage. Anastacio died during the pendency of the case, and his second wife, Araceli Vda. de Hagosojos, was substituted as defendant. Luis's full sisters were impleaded as defendants. A Compromise Agreement was executed by Araceli Vda. de Hagosojos and Luis Hagosojos, which was approved by the trial court, stipulating that the property covered by Original Certificate of Title No. P-740, including Lot No. 2736, would pertain to the children of the first marriage. Procedural History: After the judgment approving the compromise agreement had become final, the private respondents (Araceli Vda. de Hagosojos and her children from the second marriage) filed a motion to amend the decision, alleging mistake in that Lot No. 2736 could not be given to the heirs of the first marriage as it had already been donated to Henry. They proposed alternative lots. The trial court denied this motion, stating it had no power to amend a final judgment. The private respondents then filed a motion to set aside the compromise agreement and a supplemental pleading, arguing the decision had not become final and executory due to the absence of a project of partition. The trial court denied these motions. The Court of Appeals reversed the trial court's decision, setting aside the compromise agreement. The Petition: Petitioner Luis Hagosojos sought review of the Court of Appeals' decision, arguing that the appellate court erred in holding that mistake vitiated consent, that the judicial agreement could be set aside after becoming final, and that the donation of Lot No. 2736 was not void.
Issue(s)
Whether the Court of Appeals erred in holding that the private respondents committed a mistake that vitiated their consent to the Compromise Agreement. Whether the Court of Appeals erred in holding that the judicial agreement may still be set aside on the ground of mistake after it has become final and executory. Whether the Court of Appeals erred in not holding that the donation of Lot No. 2736 was null and void. Whether the Court of Appeals incurred grave abuse of discretion in failing to extend relief to Araceli and Lourdes Hagosojos.
Ruling
The petition is GRANTED. The Decision dated April 30, 1981, of the Court of Appeals is ANNULLED and SET ASIDE. The Decision dated December 5, 1975, and the Order of July 12, 1976, of the then Court of First Instance of Sorsogon in Civil Case No. 363 approving the Compromise Agreement, are REINSTATED. Costs against the private respondent Araceli H. Vda. de Hagosojos.
Ratio Decidendi
On the issue of mistake vitiating consent: The Court found the alleged mistake of respondent Araceli and her lawyer not to be a mistake at all, but rather inexcusable negligence. This negligence could not be inflicted upon the petitioner and his sisters of the full blood. The Compromise Agreement was prepared by the private respondents' lawyer without intervention from the petitioner or his counsel. Furthermore, the deed of donation was in the possession of Araceli. The Court emphasized that had she and her counsel exercised the standard of care required of an ordinarily prudent person, the controversy would have been obviated. Therefore, the alleged mistake did not vitiate consent. On the finality and executory nature of the judgment: The Court held that the respondent Court of Appeals erred in setting aside the trial court's decision approving the Compromise Agreement, as this decision had long become final and executory and could no longer be set aside or modified. The Court cited jurisprudence establishing the principle of finality of judgments. Even if there were grounds to set aside the decision, the equitable relief afforded by Rule 38 of the Rules of Court would be unavailing because the motions filed by the private respondents were filed unseasonably, exceeding the prescribed periods for filing a petition for relief from judgment. The Court stressed that the period for filing a petition for relief is absolutely fixed and inextendible. The Court also pointed out that the private respondents' motion to set aside the Compromise Agreement was fatally defective for not being verified and not accompanied by affidavits showing the mistake and the facts constituting their cause of action, which are strict requirements under Rule 38 of the Rules of Court. On the validity of the donation of Lot No. 2736: The Court found merit in the argument that the donation of Lot No. 2736 was null and void. Paragraph 3 of the Compromise Agreement explicitly stated that a liquidation and partition of properties was made on February 15, 1967, and the entire property covered by Original Certificate of Title No. P-740, including Lot No. 2736, was designated in favor of the heirs of the first marriage. Therefore, Anastacio could no longer donate Lot No. 2736 to Henry on January 22, 1973, as it had already been adjudicated. Even if Anastacio were considered among the "Heirs of the First Marriage," he could not donate a specific lot by metes and bounds, but only an aliquot part of the co-owned properties. The Court also noted that even if the liquidation date was a mistake, Anastacio could not validly donate the lot pending partition, as he only owned an aliquot part of the mass of properties co-owned with his children from the first marriage. On the failure to extend relief to other heirs: The Court found no need to further address the fourth assignment of error, stating that the trial court's decision approving the Compromise Agreement provided sufficient protection to the interests and welfare of the other children of the first marriage, private respondents Araceli Hagosojos-Alindogan and Lourdes Hagosojos-Nicolas.
Main Doctrine
A judgment approving a compromise agreement becomes final and executory upon its approval by the court and can no longer be set aside or modified, even on grounds of mistake or excusable negligence, if the remedies provided by law, such as a petition for relief from judgment, are not timely availed of.