Metro Manila Shopping Mecca Corp. vs. Toledo
G.R. No. 190818. November 10, 2014.
MAIN TOPIC – Rule 26
FACTS
Petitioners filed a Manifestation and Motion seeking the approval of the terms and conditions of the Universal Compromise Agreement (UCA) dated June 1, 2012 in lieu of the Court’s Decision dated June 5, 2013 which denied petitioners’ claim for tax refund/credit of their local business taxes. In accordance with the UCA, petitioners alleged that they agreed to amicably settle all cases between them involving claims for tax refund/credit. The UCA provides that there shall be no refunds/tax credit certificates to be given or issued by the City of Manila.
City of Manila confirmed the authenticity and due execution of the UCA however, they submitted that the UCA had no effect with the current decision since the taxes involved in the instant case was not included in the agreement
ISSUE
Whether or not the terms and conditions in hthe compromise agreement is applicable to the instant case
RULING
Yes, the local business taxes subject of the instant case is clearly covered by the UCA since they were also paid in accordance with the same provision of the Revenue Code of Manila. The UCA reveals the various court cases filed by petitioners, including this case, for the refund and/or issuance of tax credit covering the local business taxes payments they paid to respondent City of Manila pursuant to Section 21 of the latter’s Revenue Code.
A compromise agreement is a contract whereby the parties, by making reciprocal concessions, avoid a litigation or put an end to one already commenced. It contemplates mutual concessions and mutual gains to avoid the expenses of litigation; or when litigation has already begun, to end it because of the uncertainty of the result. Its validity is dependent upon the fulfillment of the requisites and principles of contracts dictated by law; and its terms and conditions must not be contrary to law, morals, good customs, public policy, and public order. When given judicial approval, a compromise agreement becomes more than a contract binding upon the parties. Having been sanctioned by the court, it is entered as a determination of a controversy and has the force and effect of a judgment. It is immediately executory and not appealable, except for vices of consent or forgery.
DOCTRINE
Compromise agreement is a contract whereby the parties, by making reciprocal concessions, avoid a litigation or put an end to one already commenced.
