Leones
v. Corpus
G.R.
No. 204106
November
17, 2021
FACTS:
Municipal Treasurer Olivia Leones,
who was temporarily detailed to the Office of the Provincial Treasurer of La
Union, was not paid her Representation and Transportation Allowances (RATA)
which prompted her to sue the officers before the RTC of San Fernando, La Union
but it was dismissed for non-exhaustion of administrative remedies. After
filing a petition for certiorari before the CA to compel the respondent to pay
her RATA, it still remained unpaid. She then filed another petition for
mandamus against incumbent Mayor Rufino Fontanilla which ended with a
compromise agreement between the two stipulating that she will be paid the
total amount representing her unpaid RATA from 1997- May 2011 and that her RATA
for the year 2011 until she retires will be given to her on a monthly basis.
Upon fulfilment of these, Leones shall obligate herself to retire from her
position on May 31, 2012. The obligation was paid in full, and on June 15, 2012
Leones found out that she was already dropped from the payrolls effective May
31, 2012 and was told to no longer report to the office. Petitioner now insists
that the compromise was null and void for being contrary to public policy and
was against property and rights exempted against execution.
ISSUE:
Whether or not the compromise
agreement was null and void.
HELD:
No, the compromise agreement was
not null and void. A compromise agreement must contain the same elements of a
valid contract: (1) consent of the parties; (2) object certain that is the
subject matter of the compromise; and (3) cause of the obligation established.
When a compromise agreement is given judicial approval, it becomes more than a
contract binding upon the parties. In this case, the compromise cannot be said
to have been tainted by any defect of will. Leones had never offered quality
proof of, or even slightly alleged, such vices of consent that could affect the
validity of the compromise agreement. If the compromise agreement would be
annulled, Leones should be aware that she must return what the Municipality of
Bacnotan had paid to her in accordance with the compromise agreement. A
cancellation of the compromise agreement would only render for naught her saga
for remuneration that had dragged on for more than a decade. Further, Leones
was not being made to give up her employment. She is already deemed to have
left her post beginning May 31, 2012 per the compromise agreement. Having been
sanctioned by the court, it is entered as a determination of a controversy and
has the force and effect of a judgment. It is immediately executory and not
appealable, except for vices of consent or forgery. The nonfulfillment of its
terms and conditions justifies the issuance of a writ of execution; in such an
instance, execution becomes a ministerial duty of the court. Thus, the
compromise agreement is not null and void.
