Magat v. Delizo
REITERATIONFacts
The Antecedents: Respondent spouses Albert and Carmina Delizo filed a complaint for specific performance against Slim Realty and Construction Inc. (SLIM) and Simon Lim, alleging that SLIM sold a property to them, and despite almost full payment, SLIM failed to deliver the title and subsequently mortgaged the property to a third party. SLIM's defense was that payment was not complete. Procedural History: The parties entered into a Compromise Agreement, which the trial court approved. The agreement stipulated that the buyer would pay the balance and the seller would deliver the title within 45 days. The trial court ordered the issuance of a writ of execution, and the property was sold to the respondent spouses as the highest bidders. The trial court later issued an order enforcing the compromise agreement and divesting SLIM of any right to the property. Subsequently, petitioners Spouses Crisostomo and Editha Magat intervened, claiming they had purchased the property from SLIM and moved to declare the proceedings null and void for lack of jurisdiction, arguing the case involved a subdivision lot exclusively cognizable by the Housing and Land Use Regulatory Board (HLURB). The Petition: The trial court, persuaded by the Magats' argument, declared all proceedings null and void for lack of jurisdiction. The Court of Appeals reversed this order, finding the intervention improper after the judgment was substantially executed. The Supreme Court reviews the Court of Appeals' decision.
Issue(s)
Whether the trial court erred in entertaining the motion for intervention filed after the judgment on compromise had been substantially executed. Whether the subject matter of the case falls under the exclusive jurisdiction of the HLURB. Whether the trial court correctly declared the proceedings null and void for lack of jurisdiction.
Ruling
The Supreme Court affirmed the Decision of the Court of Appeals, which nullified the trial court's order declaring the proceedings void for lack of jurisdiction. The Court held that the intervention was improperly allowed and that the trial court should have implemented the compromise agreement.
Ratio Decidendi
On the propriety of intervention: The Court held that the filing of the motion for intervention by the Spouses Magat was improper because it was filed after the case had already been decided on the basis of a compromise agreement and substantially executed. Under the Rules of Court, intervention may be permitted only before or during trial, or at the latest, before the rendition of judgment. Allowing intervention at such a late stage unduly delayed and disrupted the proceedings, prejudicing the rights of the original parties, especially since the intervenors' rights could be protected in a separate proceeding. The Court emphasized that the compromise agreement had already been substantially satisfied. On the jurisdiction of the HLURB: The Court found no showing that the property in question was a subdivision lot or condominium unit, which would have placed it under the exclusive jurisdiction of the HLURB. The complaint and the deed of sale described the property as a "house and lot" and did not indicate it was part of a subdivision. Therefore, the controversy was properly cognizable by the regular trial court. On the validity of the compromise agreement and the trial court's duty: The Court reiterated the axiomatic principle that a compromise agreement, once approved by the court, has the force of res judicata between the parties and should not be disturbed except for vices of consent or forgery. It is considered the contract between the parties and is immediately executory. Consequently, it was the ministerial duty of the trial court to enforce the judgment based on the compromise agreement. The grievance of the intervenor spouses Magat should have been ventilated in a separate proceeding, not by seeking to nullify the proceedings of the original case after substantial execution.
Main Doctrine
A compromise agreement, once approved by the court, has the force of res judicata and should be implemented as a matter of course, and a motion for intervention filed after the judgment on compromise has been substantially executed should not be entertained.