Amarante v. Court of Appeals
REITERATIONFacts
The Antecedents: Petitioner Mario V. Amarante was the lessee of a residential house since 1971. The lease was on a monthly basis and covered by the Rent Control Law, without a written contract. In January 1977, private respondent Antonio Valencia asked petitioner to sign a written contract limiting the lease period to December 31, 1977, which petitioner declined. Consequently, private respondent refused to accept rental payments. Procedural History: Petitioner filed a Petition for Consignation of Rentals. Private respondent moved for dismissal, which was denied, and then filed an answer. The trial court enjoined private respondent from demolishing the premises. During a hearing on July 28, 1977, the trial judge inquired if petitioner was willing to vacate. Petitioner claims he answered "yes" conditionally, while private respondent claims the acceptance was absolute. The trial judge issued an order on August 12, 1977, granting petitioner until December 1977 to vacate and ordering private respondent to accept rentals. Petitioner's motion for reconsideration was denied. He then filed a Petition for Certiorari, which was dismissed by the Regional Trial Court for being filed out of time. The Court of Appeals affirmed the dismissal, holding the August 12, 1977 order was a judgment on an oral compromise and that certiorari was not a substitute for a lost appeal. The Petition: Petitioner seeks to nullify the August 12, 1977 order, arguing it was void because his assent to vacate was conditional, constituting a mere counter-offer, and thus not an unqualified agreement or compromise. He contends the Court of Appeals erred in ruling it was a judgment based on an oral compromise.
Issue(s)
Whether the order dated August 12, 1977, is null and void, and whether it constitutes a valid judgment based on an oral compromise. Whether the trial court correctly interpreted the petitioner's manifestation regarding the compromise agreement. Whether a petition for certiorari is the proper remedy to assail the order dated August 12, 1977, when it was filed out of time, and the effect of the finality of the judgment.
Ruling
The petition is denied. The decision of the Court of Appeals affirming the trial court's order is sustained. The order of August 12, 1977, is deemed a valid judgment based on an oral compromise and has become final and executory.
Ratio Decidendi
On the validity of the order and its nature as an oral compromise: The Supreme Court sustained the Court of Appeals, holding that the order of August 12, 1977, was issued based on the manifestations made by the parties during the hearing of July 28, 1977. Specifically, the petitioner's statement of willingness to vacate by December 1977 was considered by the trial judge. The records did not disclose any condition imposed by the petitioner to his assent, and private respondent agreed to accept the rentals, effectively terminating the consignation action. Therefore, the order was correctly considered a valid judgment based on an oral compromise, which is generally favored and binding if parties acted in good faith with reciprocal concessions. On the interpretation of petitioner's manifestation: The Court held that whether the trial court correctly interpreted petitioner's manifestation is a question of fact that is no longer triable on appeal. The impressions of the trial judge, who had the opportunity to observe the parties' demeanor, are accorded more weight, and in the absence of arbitrariness, are considered conclusive. The Court noted that petitioner himself admitted to murmuring his condition in open court in a faint manner, suggesting it was not intended to be heard or was not effectively communicated as a qualification to his assent. The trial court's ruling explicitly stated petitioner's manifestation was without qualification. On the propriety of the remedy and finality of judgment: The Court affirmed the dismissal of the petition for certiorari. Petitioner failed to appeal the trial court's order and instead filed a certiorari petition, which was dismissed for being filed out of time. Certiorari cannot be a substitute for a lost appeal. Consequently, the order approving the compromise agreement became final and executory upon the lapse of the reglementary period to appeal without an appeal being perfected. A final judgment is conclusive as to all matters litigated and those that could have been litigated as incidents of the original action.
Main Doctrine
An order of the trial court, issued based on manifestations made by the parties during a hearing, which is considered by the appellate court as a judgment based on an oral compromise, is valid and binding. Any error therefrom must be rectified by an appeal, not by a petition for certiorari, especially when the petition is filed out of time.