Case Digest: Lacson v. MJ Lacson Development Company

G.R. No. 168840 : December 8, 2010




Respondent MJ Lacson Development Company, Inc. is a corporation engaged in the business of sugar production. It owns and operates Hacienda San Benito in Moises Padilla, Negros Occidental. It filed before the Regional Trial Court (RTC) of Negros Occidental in Bacolod City a Complaint for Injunction with Preliminary Mandatory Injunction, Accounting and Damages against petitioner Enrique Miguel Lacson.

The parties were thereafter able to arrive at an Amicable Settlement. They submitted Amicable Settlement for the trial courts approval and same was eventually approved through a Judgment by Compromise. Just less than a month after said approval, however, petitioner filed a Motion for Partial Modification of the Judgment by Compromise. Petitioner believed that there was a need to partially modify the conditions of the Amicable Settlement by proportionately reducing the amount covered by the promissory note which he would execute in favor of respondent.

Respondent filed its Opposition to said motion and at the same time a Motion for Execution. In said Opposition, respondent emphasized that the subject amicable settlement was freely and voluntarily entered into by the parties with the assistance of their respective counsels and that the Judgment by Compromise is final and immediately executory.

Trial court granted respondents Motion for Execution, in effect denying petitioners Motion for Partial Modification of the Judgment by Compromise. Petitioner filed a motion for reconsideration but the same was denied. Thus, petitioner went to the CA by way of petition for certiorari.

The CA stressed the well-settled rule that the finality of a judgment based on a compromise agreement, would, as a matter of right, make the issuance of an order for the execution of said judgment a mere ministerial duty on the part of the court a quo. Petitioner filed a motion for reconsideration but the same was denied. Hence, this petition.

ISSUE: Whether or not petitioner was denied due process when he was deprived to present evidence in support of his motion for partial modification of the judgment by compromise

HELD: No. CA Decision Affirmed.

POLITICAL LAW- Denial of due process means the total lack of opportunity to be heard or to have ones day in court. There is no denial of due process where a party has been given an opportunity to be heard and to present his case.

Here, petitioner alleges that the trial court conducted a hearing on his Motion for Partial Modification of the Judgment by Compromise. Clearly, he was given the opportunity to be heard thereon. The failure of the lower court to rule on his oral motion to present evidence during said hearing is not denial of due process. The fact is that the trial court heard his motion for partial modification and his failure to present further evidence to support the same cannot be equated with lack of due process.

Besides, respondent, in its Memorandum advances a plausible explanation for the trial courts failure to rule on petitioners oral motion to allow him to present evidence, that is, petitioner was ordered by the trial court to reduce into writing his oral motion but he did not do so. Petitioner did not dispute this allegation in his Memorandum despite his having the opportunity to do so, since as shown by the records, respondent served upon petitioner a copy of its memorandum way ahead of petitioners filing before this Court of his own memorandum.