Perciano v. Tumbali
REITERATIONFacts
1. The Antecedents: The underlying dispute originated from Civil Case No. 2603 for Reconveyance with Damages, where the Regional Trial Court (RTC) of Tuguegarao City dismissed the complaint filed by Enrica and Sofia Garunay. The RTC also ordered the plaintiffs to vacate a property of 9,394 square meters in Buntun, Tuguegarao City, based on a counterclaim judgment in favor of the heirs of spouses Vicente Coballes and Juana Matammu. 2. Procedural History: When the defendants in Civil Case No. 2603 attempted to execute the decision, it was discovered that Guillermo Perciano, Jr., who was not a party to the original case, occupied a portion of the disputed property. Perciano, Jr. then filed a special civil action for certiorari with the Court of Appeals (CA), seeking a temporary restraining order and a writ of preliminary injunction. The CA denied this petition for lack of merit. 3. The Petition: Aggrieved by the CA's denial, petitioner Guillermo Perciano, Jr. filed the present petition for review on certiorari with the Supreme Court. During the pendency of this petition, the parties submitted a Compromise Agreement, wherein Perciano, Jr. acknowledged Lydia Tumbali's ownership of the land, but Tumbali ceded 208 square meters of the southern portion to Perciano, Jr. The agreement stipulated that Tumbali would transfer the title of this portion to Perciano, Jr. at her expense, and Perciano, Jr. would relocate his house upon title transfer. The parties also waived claims for damages. The Supreme Court, finding the Compromise Agreement in order and not contrary to law, morals, good customs, and public policy, rendered judgment in accordance with its terms.
Issue(s)
Whether the Compromise Agreement submitted by the parties should be approved. Whether the CA erred in denying the petition for certiorari.
Ruling
The Supreme Court approved the Compromise Agreement and rendered judgment in accordance with its terms and conditions, enjoining the parties to comply strictly and in good faith with the stipulations therein.
Ratio Decidendi
On the approval of the Compromise Agreement: The Court found the Compromise Agreement to be in order and not contrary to law, morals, good customs, and public policy. The agreement stipulated that petitioner Guillermo Perciano, Jr. acknowledged the absolute ownership and right of possession of respondent Lydia Tumbali over the parcel of land covered by TCT No. T-67236. However, respondent Lydia Tumbali ceded, transferred, and conveyed 208 square meters of the southern portion of the said parcel to petitioner. Respondent Tumbali also agreed to shoulder the expense of transferring the title of the 208 square meters to petitioner's name. Petitioner agreed to relocate his house once the title transfer is completed and the owner's duplicate copy of the title is surrendered to him. Both parties waived their claims for damages. The Court noted that Lydia Tumbali had submitted a Deed of Reconveyance and a Manifestation and Motion, clarifying that the property was already titled in her name since June 2, 1986, by virtue of an extrajudicial settlement of estate among the heirs of Procopio Tumbali. Given these circumstances, the Court found judicial approval of the Compromise Agreement to be in order. On the denial of the petition for certiorari: While not explicitly discussed as a separate issue in the ratio, the approval of the Compromise Agreement effectively resolved the dispute that led to the petition for certiorari. The Court's action of rendering judgment based on the compromise agreement rendered the CA's denial of the petition moot and academic in the context of the original dispute, as the parties themselves have settled their differences.
Main Doctrine
A compromise agreement, when found to be in order and not contrary to law, morals, good customs, and public policy, shall be judicially approved and shall have the force of law between the parties.