QUIROS v.

ARJONA
G.R. No. 158901; 9 MARCH 2004
Petition for review on certiorari of CA decision
Justice Ynares-Santiago
FACTS:
Petitioners Proceso Quiros and Leonarda Villegas filed with the office of the Brgy. Captain
of Labney, San Jacinto, Pangasinan, a complaint for recovery of ownership and possession
of a parcel of land against their uncle Marcelo Arjona (one of the respondents). The subject
land was their lawful share/inheritance from their late grandmother.
The parties eventually reached an amicable settlement. By reason thereof, Arjona
executed a document/agreement which states that he will give to petitioners the 1 hectare
land he inherited from his mother. Another document/agreement was executed by a Jose
Banda which states that the land he is cultivating/tilling belongs to the Arjona family, and
that he will voluntarily surrender said land if ever the petitioners would get it from him.
Petitioners filed a complaint with the MCTC for the execution of the compromise
agreement, which was denied because the subject property cannot be determined with
certainty.
On appeal, the RTC reversed the decision.
Respondents appealed to the CA which reversed the decision of the trial court.
ISSUE:Whether the amicable settlement between the parties is valid and enforceable.
HELD: NO.
RATIO:
The Court held that the general rule regarding the finality of amicable settlements (which
is: where no repudiation was made during the 10-day period, such settlement attains the status of
finality and the courts have the ministerial duty to implement and enforce it) admits certain
exceptions; such as those special and exceptional circumstances or facts that may have
transpired after the finality of judgment and which would render its execution unjust. 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. Perusal of the 2 documents of
the amicable settlement show that the lands referred to were different from each other.
Hence, no writ of execution could be issued for failure to determine with certainty what
parcel of land respondent intended to convey.

An amicable settlement partakes of the nature of a contract. Thus, it is subject to the

same legal provisions providing for the validity, enforcement, rescission or annulment of
ordinary contracts i.e. there is a need to ascertain whether said documents sufficiently
complied with the requisites of validity in accordance with Art. 1318, NCC.
o CONSENT: There is no question that there was meeting of the minds between the
contracting parties.
o OBJECT: The object is a 1-hectare parcel of land that the petitioners inherited from
their grandmother.
o CAUSE: The cause of the contract is the delivery of petitioners share in the
inheritance.

NOTE: The inability to identify the land did not negate the principal object of the contract.
Such error may be corrected by reformation of the instrument and not its nullification.

Reformation is a remedy in equity whereby a written instrument is made or construed so

as to express or conform to the real intention of the parties where some error or mistake
has been committed. In granting reformation, the remedy in equity is not making a new
contract for the parties, but establishing and perpetuating the real contract between the
parties which, under the technical rules of law, could not be enforced but for such
reformation.
 In order that an action for reformation of instrument as provided in Article 1359 of the Civil
Code may prosper, the following requisites must concur: (1) there must have been a
meeting of the minds of the parties to the contract; (2) the instrument does not express
the true intention of the parties; and (3) the failure of the instrument to express the true
intention of the parties is due to mistake, fraud, inequitable conduct or accident.