Hagosojos vs. Court of Appeals

A compromise agreement approved by the court becomes final and executory immediately upon approval and cannot be set aside on grounds of mistake or excusable negligence if the petition for relief under Rule 38 is not filed within the reglementary periods. Additionally, a donation of specific property from a co-owned mass, made after an alleged liquidation and partition has designated the property to others, is null and void.

The dispute centered on the conjugal partnership assets of Anastacio Hagosojos's first marriage to Jacinta Jaucian. Upon Jacinta's death in 1959, the conjugal partnership assets should have been partitioned among her surviving spouse and their three children (Luis, Araceli, and Lourdes). Instead, Anastacio remarried in 1965 and had three more children. In 1973, Anastacio donated a large portion of the first marriage's conjugal assets (Lot No. 2736) to his minor son from the second marriage, Henry. This led to a lawsuit filed by the first marriage's children to compel partition.

• Initial complaint filed by Luis Hagosojos and his two sisters in the Court of First Instance (CFI) of Sorsogon.
• The case was pending when Anastacio died, leading to an amended complaint.
• The parties submitted a compromise agreement to the CFI for approval.
• The CFI approved the compromise agreement on December 5, 1975.
• Respondents filed a "Motion to Amend Decision Based on Mistake," which was denied on June 18, 1976.
• Respondents filed a "Motion to Set Aside Compromise Agreement," which was also denied on July 12, 1976.
• Respondents appealed to the Court of Appeals (CA).
• The CA reversed the CFI's decisions on April 30, 1981.
• Luis Hagosojos filed the instant petition for review on certiorari in the Supreme Court.

• Anastacio Hagosojos had two wives: Jacinta (first) and Araceli (second).
• From the first marriage, he had three children: Luis Hagosojos (petitioner), Araceli Hagosojos-Alindogan, and Lourdes Hagosojos-Nicolas.
• From the second marriage, he had three children: Fred, Heidi, and Henry Hagosojos.
• In 1973, Anastacio donated Lot No. 2736 (part of the first marriage's conjugal assets) to his minor son, Henry.
• Luis and his two sisters filed a complaint to partition the conjugal assets of the first marriage.
• A compromise agreement was signed by Luis and Araceli (stepmother) and submitted to the court, which approved it in 1975.
• Respondents claimed they mistakenly omitted Lot No. 2736 from the compromise agreement and filed a motion to amend/set it aside.

• The alleged mistake was not a legal mistake but inexcusable negligence, as the deed of donation was in the respondents' possession.
• The decision approving the compromise agreement was already final and executory, making it unassailable.
• The donation of Lot No. 2736 was null and void because the property had been liquidated and partitioned in 1967, and a co-owner cannot donate a specific lot from a common mass.

• Their consent to the compromise agreement was vitiated by a mutual mistake of fact, as they forgot about the prior donation to Henry.
• The judgment had not become final and executory because no project of partition had been submitted and approved.

• Procedural Issues:
  • Whether the Court of Appeals erred in setting aside a final and executory judgment.
  • Whether the respondents' motions were timely filed under Rule 38 of the Rules of Court.
• Substantive Issues:
  • Whether the compromise agreement could be set aside on the ground of mistake.
  • Whether the donation of Lot No. 2736 to Henry Hagosojos was valid.

• Procedural:
  • The Supreme Court ruled that the Court of Appeals gravely erred in setting aside the final and executory decision of the trial court. The respondents' motions, even if treated as petitions for relief under Rule 38, were filed beyond the 60-day reglementary period. The equitable maxim "equity aids the vigilant, not those who slumber on their rights" applies.
• Substantive:
  • The Supreme Court held that the alleged mistake was not a legal mistake but inexcusable negligence, which cannot vitiate consent or justify the setting aside of a compromise agreement. The donation to Henry was null and void because the property had already been partitioned and adjudicated to the heirs of the first marriage in the compromise agreement. As a co-owner, Anastacio could only donate an aliquot share of the common mass, not a specific lot.

• Finality of Judgments — A judgment that is final and executory is no longer subject to change, modification, or reversal, except through very narrow exceptions like a petition for relief under Rule 38. The Court emphasized that the grace period under Rule 38 is "absolutely fixed, inextendible, never interrupted and cannot be subject to any condition or contingency."
• Equitable Maxim: "Equity aids the vigilant, not those who slumber on their rights" — Courts will not grant equitable relief to a party who has failed to diligently protect their rights within the prescribed legal periods.
• Rule 38, Rules of Court (Petition for Relief from Judgment) — This rule allows a party to seek relief from a judgment due to fraud, accident, mistake, or excusable negligence, but only if the petition is filed within the strict periods of 60 days from knowledge and 6 months from entry of judgment, and must be verified and accompanied by supporting affidavits.
• Co-ownership — Upon the death of a spouse, the conjugal partnership assets become a co-ownership among the surviving spouse and the children. A co-owner cannot validly donate a specific portion of the common mass but only an undivided share.
• Principle of "Equity follows the law" — While equity can provide a remedy where the law is silent, it cannot extend or modify a specific legal remedy that is bounded by rules, such as the strict requirements of Rule 38.

• "It is more of negligence, which is inexcusable, and certainly can not be inflicted on the petitioner and his sisters of the full blood."
• "The doctrine of finality of judgments is grounded on fundamental considerations of public policy and sound practice that at the risk of occasional error the judgments of courts must become final at some definite date fixed by law."
• "The equitable remedy is an act of grace, as it were, designed to give the aggrieved party another and last chance and failure to avail of such last chance within the grace period fixed by the statute or Rules of Court is fatal."

• De los Reyes vs. Ugarte (75 Phil. 505) — Cited to affirm the principle that a judgment on compromise is final and executory upon approval.
• Philippine Rabbit Bus Lines, Inc. vs. Hon. Ludivico D. Arciaga (No. L-29701, March 16, 1987) — Cited for the strict application of Rule 38 periods, where a petition filed one day late was denied.
• Turqueza vs. Hernando (97 SCRA 488 [1980]) — Cited for the doctrine that the Rule 38 period is "absolutely fixed, inextendible."
• Arcilla vs. Arcilla (138 SCRA 566 [1985]) — Cited for the requirement that a petition for relief must strictly comply with Rule 38 provisions.
• Mercado vs. Liwanag (No. L-14429, June 20, 1962, 5 SCRA 472) — Cited for the principle that a co-owner can only dispose of an aliquot share of the common mass.

• Rule 38, Sections 2 and 3, Revised Rules of Court — The court applied the strict requirements for filing a petition for relief from judgment, emphasizing the 60-day and 6-month periods and the need for verification and supporting affidavits.
• Article on Co-ownership from the Civil Code — While not explicitly cited by article number, the court's reasoning on co-ownership and the limitations on a co-owner's power to dispose of common property is based on Civil Code provisions.