Quiros and Villegas vs. Arjona et. al.

PROCESO QUIROS and LEONARDA VILLEGAS vs. MARCELO ARJONA, TERESITA BALARBAR, JOSEPHINE ARJONA, and CONCHITA ARJONA
G.R. No. 158901. 9 March 2004.
Petition for review of the decision of the CA
Ynares-Santiago, J.:

Facts: In Dec 1996, petitioners Proceso Quiros and Leonarda Villegas filed with the office of the barangay captain of Labney, San Jacinto, Pangasinan, a complaint for recovery of ownership and possession of a parcel of land located at Labney, San Jacinto, Pangasinan. Petitioners sought to recover from their uncle Marcelo Arjona, one of the respondents herein, their lawful share of the inheritance from their late grandmother Rosa Arjona Quiros alias Doza. In 1997, an amicable settlement was reached between the parties. By reason thereof, respondent Arjona executed a document denominated as "PAKNAAN" ("Agreement", in Pangasinan dialect).
Petitioners filed a complaint with the MCTC with prayer for the issuance of a writ of execution of the compromise agreement which was denied because the subject property cannot be determined with certainty. The RTC reversed the decision of the municipal court on appeal and ordered the issuance of the writ of execution. Respondents appealed to the CA, which reversed the decision of the RTC and reinstated the decision of the MCTC.

Issue: WON CA erred in reversing the decision of the RTC and reinstating that of the MCTC.

Ruling: Petition denied.
Generally, the rule is that where no repudiation was made during the 10-day period, the amicable settlement attains the status of finality and it becomes the ministerial duty of the court to implement and enforce it. However, such rule is not inflexible for it admits of certain exceptions. In the case at bar, the ends of justice would be frustrated if a writ of execution is issued considering the uncertainty of the object of the agreement. To do so would open the possibility of error and future litigations.
Both parties acknowledge that petitioners are entitled to their inheritance, hence, the remedy of nullification, which invalidates the Paknaan, would prejudice petitioners and deprive them of their just share of the inheritance. Respondent cannot, as an afterthought, be allowed to renege on his legal obligation to transfer the property to its rightful heirs. A refusal to reform the Paknaan under such circumstances would have the effect of penalizing one party for negligent conduct, and at the same time permitting the other party to escape the consequences of his negligence and profit thereby. No person shall be unjustly enriched at the expense of another.

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