Lawyerly

GR No. 172139

2010-12-08

DEL CASTILLO, J.

Clearly, by her own acts, Jocelyn is estopped from impugning the validity of the "Acknowledgment of Debt." "[A] party to a contract cannot deny the validity thereof after enjoying its benefits without outrage to one's sense of justice and fairness."[21] "It is a long established doctrine that the law does not relieve a party from the effects of an unwise, foolish or disastrous contract, entered into with all the required formalities and with full awareness of what she was doing. Courts have no power to relieve parties from obligations voluntarily assumed, simply because their contracts turned out to be disastrous or unwise investments."[22]

GR No. 183591

2008-10-14

PROVINCE OF NORTH COTABATO v. GOVERNMENT OF REPUBLIC PEACE PANEL ON ANCESTRAL DOMAIN

CARPIO MORALES, J.

The power of judicial review is limited to actual cases or controversies.[54] Courts decline to issue advisory opinions or to resolve hypothetical or feigned problems, or mere academic questions.[55] The limitation of the power of judicial review to actual cases and controversies defines the role assigned to the judiciary in a tripartite allocation of power, to assure that the courts will not intrude into areas committed to the other branches of government.[56]

GR NO. 158563

2006-06-30

AIR TRANSPORTATION OFFICE v. APOLONIO GOPUCO

CHICO-NAZARIO, J.

As to respondent's first and second arguments, we have time and again ruled that a compromise agreement, when not contrary to law, public order, public policy, morals, or good customs, is a valid contract which is the law between the parties.[26] It is a contract perfected by mere consent,[27] whereby the parties, making reciprocal concessions, avoid litigation or put an end to one already commenced. It has the force of law and is conclusive between the parties,[28] and courts will not relieve parties from obligations voluntarily assumed, simply because their contracts turned out to be unwise.[29] Note that respondent has not shown that any of the compromise agreements were in any way tainted with illegality, irregularity or imprudence. Indeed, anyone who is not a party to a contract or agreement cannot be bound by its terms, and cannot be affected by it.[30] Since Gopuco was not a party to the compromise agreements, he cannot legally invoke the same.[31]

GR NO. 144732

2006-02-13

ROLANDO LIMPO v. CA

AZCUNA, J.

A compromise agreement once approved by order of the court becomes immediately final and executory with the force of res judicata.[8] The court's sanction imbues it with the same effect as any other judgment.[9] No doubt that as to the spouses Uy, there was a clear declaration of liability. Debate arises with respect to Limpo who was never mentioned in both the agreement and the judgment despite that fact that he was impleaded as a defendant. How should this omission affect him?

GR NO. 160966

2005-10-11

PAGODA PHILIPPINES v. UNIVERSAL CANNING

PANGANIBAN, J.

At the outset, we note that petitioner, in an effort to cover its bases, filed the present Petition as both a petition for review under Rule 45 and a petition for certiorari under Rule 65 of the Rules of Court. The applicable rule is Rule 45, which clearly provides that decisions, final orders or resolutions of the CA in any case -- regardless of the nature of the action or proceeding involved -- may be appealed to this Court through a petition for review. This remedy is a continuation of the appellate process over the original case.[7] "It is basic that where Rule 45 is available, and in fact availed of as a remedy -- as in this case -- recourse under Rule 65 cannot be allowed either as an add-on or as a substitute for appeal."[8]

GR No. 158563

2005-06-30

AIR TRANSPORTATION OFFICE v. APOLONIO GOPUCO

CHICO-NAZARIO, J.

contract perfected by mere consent,[27] whereby the parties, making reciprocal concessions, avoid litigation or put an end to one already commenced. It has the force of law and is conclusive between the parties,[28] and courts will not relieve parties from obligations voluntarily assumed, simply because their contracts turned out to be unwise.[29] Note that respondent has not shown that any of the compromise agreements were in any way tainted with illegality, irregularity or imprudence. Indeed, anyone who is not a party to a contract or agreement cannot be bound by its terms, and cannot be affected by it.[30] Since Gopuco was not a party to the compromise agreements, he cannot legally invoke the same.[31] Lastly, Gopuco argues that there is present, in cases of expropriation, an "implied contract" that the properties will be used only for the public purpose for which they were acquired. No such contract exists.

GR NO. 153904

2005-01-17

PNOC-EDC v. FREDERICK V. ABELLA

CHICO-NAZARIO, J.

Prevailing case law provides that "a compromise once approved by final orders of the court has the force of res judicata between the parties and should not be disturbed except for vices of consent or forgery. Hence, 'a decision on a compromise agreement is final and executory.' Such agreement has the force of law and is conclusive on the parties. It transcends its identity as a mere contract binding only upon the parties thereto, as it becomes a judgment that is subject to execution in accordance with the Rules. Judges therefore have the ministerial and mandatory duty to implement and enforce it."[38] (Underlining supplied.) Hence, compromise agreements duly approved by the courts are considered the decisions in the particular cases they involve.[39]

GR No. 147349

2004-02-13

MANILA INTERNATIONAL AIRPORT AUTHORITY v. ALA INDUSTRIES CORPORATION

PANGANIBAN, J.

In a long line of cases, we have consistently held that "x x x 'a compromise once approved by final orders of the court has the force of res judicata[16] between the parties and should not be disturbed except for vices of consent or forgery.' Hence, 'a decision on a compromise agreement is final and executory x x x.'"[17] Such agreement has the force of law[18] and is conclusive between the parties.[19] It transcends its identity as a mere contract binding only upon the parties thereto, as it becomes a judgment that is subject to execution in accordance with the Rules.[20] Judges therefore have the ministerial and mandatory duty to implement and enforce it.[21]

GR No. 147349

2004-02-13

MANILA INTERNATIONAL AIRPORT AUTHORITY v. ALA INDUSTRIES CORPORATION

PANGANIBAN, J.

The lower court was without power to relieve petitioner from an obligation it had voluntarily assumed, simply because the Agreement later turned out to be unwise, disastrous or foolish.[46] It had no authority to impose upon the parties a judgment different from or against the terms and conditions of their Compromise Agreement.[47] It could not alter a contract by construction or make a new one for the parties; "its duty is confined to the interpretation of the one which they have made for themselves without regard to its wisdom or folly as the court cannot supply material stipulations or read into the contract words which it does not contain."[48] It could not even set aside its judgment without declaring in an incidental hearing that the Agreement was vitiated by any of the grounds enumerated in Article 2038 of the Civil Code.[49] Above all, neither the Agreement nor the court's approval of it was ever questioned or assailed by the parties.

GR No. 144214

2003-07-14

LUZVIMINDA J. VILLAREAL v. DONALDO EFREN C. RAMIREZ

PANGANIBAN, J.

It is a long established doctrine that the law does not relieve parties from the effects of unwise, foolish or disastrous contracts they have entered into with all the required formalities and with full awareness of what they were doing. Courts have no power to relieve them from obligations they have voluntarily assumed, simply because their contracts turn out to be disastrous deals or unwise investments.[29]

GR No. 136031

2002-01-04

JEFFERSON LIM v. QUEENSLAND TOKYO COMMODITIES

QUISUMBING, J.

It appears that petitioner's reason to back out of the agreement is that he began sustaining losses from the trade. However, this alone is insufficient to nullify the contract or disregard its legal effects. By its very nature it is already a perfected, if not a consummated, contract. Courts have no power to relieve parties from obligations voluntarily assumed, simply because their contracts turned out to be disastrous or unwise investments.[33] Notably, in the Customer's Agreement, petitioner has been forewarned of the high risk involved in the foreign currency investment as stated in the "Risk Disclosure Statement," [34] located in the same box where petitioner signed.

	GR No. 172139 2010-12-08	JOCELYN M. TOLEDO v. MARILOU M. HYDEN DEL CASTILLO, J.
Clearly, by her own acts, Jocelyn is estopped from impugning the validity of the "Acknowledgment of Debt." "[A] party to a contract cannot deny the validity thereof after enjoying its benefits without outrage to one's sense of justice and fairness."[21] "It is a long established doctrine that the law does not relieve a party from the effects of an unwise, foolish or disastrous contract, entered into with all the required formalities and with full awareness of what she was doing. Courts have no power to relieve parties from obligations voluntarily assumed, simply because their contracts turned out to be disastrous or unwise investments."[22]
	GR No. 183591 2008-10-14	PROVINCE OF NORTH COTABATO v. GOVERNMENT OF REPUBLIC PEACE PANEL ON ANCESTRAL DOMAIN CARPIO MORALES, J.
The power of judicial review is limited to actual cases or controversies.[54] Courts decline to issue advisory opinions or to resolve hypothetical or feigned problems, or mere academic questions.[55] The limitation of the power of judicial review to actual cases and controversies defines the role assigned to the judiciary in a tripartite allocation of power, to assure that the courts will not intrude into areas committed to the other branches of government.[56]
	GR NO. 158563 2006-06-30	AIR TRANSPORTATION OFFICE v. APOLONIO GOPUCO CHICO-NAZARIO, J.
As to respondent's first and second arguments, we have time and again ruled that a compromise agreement, when not contrary to law, public order, public policy, morals, or good customs, is a valid contract which is the law between the parties.[26] It is a contract perfected by mere consent,[27] whereby the parties, making reciprocal concessions, avoid litigation or put an end to one already commenced. It has the force of law and is conclusive between the parties,[28] and courts will not relieve parties from obligations voluntarily assumed, simply because their contracts turned out to be unwise.[29] Note that respondent has not shown that any of the compromise agreements were in any way tainted with illegality, irregularity or imprudence. Indeed, anyone who is not a party to a contract or agreement cannot be bound by its terms, and cannot be affected by it.[30] Since Gopuco was not a party to the compromise agreements, he cannot legally invoke the same.[31]
	GR NO. 144732 2006-02-13	ROLANDO LIMPO v. CA AZCUNA, J.
A compromise agreement once approved by order of the court becomes immediately final and executory with the force of res judicata.[8] The court's sanction imbues it with the same effect as any other judgment.[9] No doubt that as to the spouses Uy, there was a clear declaration of liability. Debate arises with respect to Limpo who was never mentioned in both the agreement and the judgment despite that fact that he was impleaded as a defendant. How should this omission affect him?
	GR NO. 160966 2005-10-11	PAGODA PHILIPPINES v. UNIVERSAL CANNING PANGANIBAN, J.
At the outset, we note that petitioner, in an effort to cover its bases, filed the present Petition as both a petition for review under Rule 45 and a petition for certiorari under Rule 65 of the Rules of Court. The applicable rule is Rule 45, which clearly provides that decisions, final orders or resolutions of the CA in any case -- regardless of the nature of the action or proceeding involved -- may be appealed to this Court through a petition for review. This remedy is a continuation of the appellate process over the original case.[7] "It is basic that where Rule 45 is available, and in fact availed of as a remedy -- as in this case -- recourse under Rule 65 cannot be allowed either as an add-on or as a substitute for appeal."[8]
	GR No. 158563 2005-06-30	AIR TRANSPORTATION OFFICE v. APOLONIO GOPUCO CHICO-NAZARIO, J.
contract perfected by mere consent,[27] whereby the parties, making reciprocal concessions, avoid litigation or put an end to one already commenced. It has the force of law and is conclusive between the parties,[28] and courts will not relieve parties from obligations voluntarily assumed, simply because their contracts turned out to be unwise.[29] Note that respondent has not shown that any of the compromise agreements were in any way tainted with illegality, irregularity or imprudence. Indeed, anyone who is not a party to a contract or agreement cannot be bound by its terms, and cannot be affected by it.[30] Since Gopuco was not a party to the compromise agreements, he cannot legally invoke the same.[31] Lastly, Gopuco argues that there is present, in cases of expropriation, an "implied contract" that the properties will be used only for the public purpose for which they were acquired. No such contract exists.
	GR NO. 153904 2005-01-17	PNOC-EDC v. FREDERICK V. ABELLA CHICO-NAZARIO, J.
Prevailing case law provides that "a compromise once approved by final orders of the court has the force of res judicata between the parties and should not be disturbed except for vices of consent or forgery. Hence, 'a decision on a compromise agreement is final and executory.' Such agreement has the force of law and is conclusive on the parties. It transcends its identity as a mere contract binding only upon the parties thereto, as it becomes a judgment that is subject to execution in accordance with the Rules. Judges therefore have the ministerial and mandatory duty to implement and enforce it."[38] (Underlining supplied.) Hence, compromise agreements duly approved by the courts are considered the decisions in the particular cases they involve.[39]
	GR No. 147349 2004-02-13	MANILA INTERNATIONAL AIRPORT AUTHORITY v. ALA INDUSTRIES CORPORATION PANGANIBAN, J.
In a long line of cases, we have consistently held that "x x x 'a compromise once approved by final orders of the court has the force of res judicata[16] between the parties and should not be disturbed except for vices of consent or forgery.' Hence, 'a decision on a compromise agreement is final and executory x x x.'"[17] Such agreement has the force of law[18] and is conclusive between the parties.[19] It transcends its identity as a mere contract binding only upon the parties thereto, as it becomes a judgment that is subject to execution in accordance with the Rules.[20] Judges therefore have the ministerial and mandatory duty to implement and enforce it.[21]
	GR No. 147349 2004-02-13	MANILA INTERNATIONAL AIRPORT AUTHORITY v. ALA INDUSTRIES CORPORATION PANGANIBAN, J.
The lower court was without power to relieve petitioner from an obligation it had voluntarily assumed, simply because the Agreement later turned out to be unwise, disastrous or foolish.[46] It had no authority to impose upon the parties a judgment different from or against the terms and conditions of their Compromise Agreement.[47] It could not alter a contract by construction or make a new one for the parties; "its duty is confined to the interpretation of the one which they have made for themselves without regard to its wisdom or folly as the court cannot supply material stipulations or read into the contract words which it does not contain."[48] It could not even set aside its judgment without declaring in an incidental hearing that the Agreement was vitiated by any of the grounds enumerated in Article 2038 of the Civil Code.[49] Above all, neither the Agreement nor the court's approval of it was ever questioned or assailed by the parties.
	GR No. 144214 2003-07-14	LUZVIMINDA J. VILLAREAL v. DONALDO EFREN C. RAMIREZ PANGANIBAN, J.
It is a long established doctrine that the law does not relieve parties from the effects of unwise, foolish or disastrous contracts they have entered into with all the required formalities and with full awareness of what they were doing. Courts have no power to relieve them from obligations they have voluntarily assumed, simply because their contracts turn out to be disastrous deals or unwise investments.[29]
	GR No. 136031 2002-01-04	JEFFERSON LIM v. QUEENSLAND TOKYO COMMODITIES QUISUMBING, J.
It appears that petitioner's reason to back out of the agreement is that he began sustaining losses from the trade. However, this alone is insufficient to nullify the contract or disregard its legal effects. By its very nature it is already a perfected, if not a consummated, contract. Courts have no power to relieve parties from obligations voluntarily assumed, simply because their contracts turned out to be disastrous or unwise investments.[33] Notably, in the Customer's Agreement, petitioner has been forewarned of the high risk involved in the foreign currency investment as stated in the "Risk Disclosure Statement," [34] located in the same box where petitioner signed.

JULIETA V. ESGUERRA v. CA