LAND BANK OF THE PHILIPPINES v.
HEIRS OF SPOUSES JORJA RIGOR-
SORIANO AND MAGIN SORIANO, NAMELY: MARIVEL S. CARANDANG
AND JOSEPH SORIANO. (G.R. No. 178312; January 30, 2013).
FACTS: Marivel Carandang and Joseph Soriano are the children of the late Sps. Jorja
Rigor- Soriano and Magin Soriano, the owners of the two parcels of land located in
Macabucod, Aliaga, Nueva Ecija. The properties became subject to Operation Land
Transfer (OLT) and were valued by the Land Bank and the Department of Agrarian
Reform (DAR) at P10,000.00/hectare. Contending that such valuation was too low
compared to existing valuations of agricultural lands, the heirs commenced an action for
just compensation. They asked that a final valuation of the properties be pegged at
P1,800,000.00, based on Administrative Order No. 61, Series of 1992 and R.A. No.
6657.
The RTC ordered Land Bank to pay the heirs the amount P1,227,571.10 as just
compensation. Land Bank appealed to the CA. The CA denied the petition. Hence, Land
Bank appealed to the Supreme Court.
During the pendency of the appeal, both parties entered into an agreement re-evaluating
the cost of the parcels of land. Thus, Land Bank submitted a manifestation informing
the High Court that the parties have already filed their Joint Motion to Approve
submitting their Agreement dated November 29, 2012.
ISSUE: Should the present appeal to the Supreme Court be dismissed?
HELD: The Agreement was a compromise that the parties freely and voluntarily
entered into for the purpose of finally settling their dispute in this case. Under Art. 2028
of the Civil Code, a compromise is a contract whereby the parties, by making reciprocal
concessions, avoid a litigation or put an end to one already commenced. Accordingly, a
compromise is either judicial, if the objective is to put an end to a pending litigation, or
extrajudicial, if the objective is to avoid a litigation. Indeed, with the respondents
thereby expressly signifying their unconditional or absolute acceptance and full receipt
of the foregoing amounts as just compensation for the subject properties, the case
pending before the SC is hereby closed and terminated. The ultimate objective of the
action to determine just compensation for the landowners was achieved.
As a contract, a compromise is perfected by mutual consent. However, a judicial
compromise, while immediately binding between the parties upon its execution, is not
executory until it is approved by the court and reduced to a judgment. The validity of a
compromise is dependent upon its compliance with the requisites and principles of
contracts dictated by law. Also, the terms and conditions of a compromise must not be
contrary to law, morals, good customs, public policy and public order. A review of the
terms of the Agreement, indicates that it is a judicial compromise because the parties
intended it to terminate their pending litigation by fully settling their dispute.