Spouses Inocencio v. Court of Appeals

Summary

This case involves enforcement of a court-approved compromise agreement between creditor and debtor spouses regarding property redemption. The Geronimo spouses borrowed P2,019,859 secured by mortgage on two land parcels. After foreclosure, they entered a compromise requiring payment of P2,000,000 for one property and transfer of three smaller parcels within six months for the other. While they paid the money and redeemed the first property, they delivered the required land titles seven days late. The Supreme Court ruled that compromise agreements have the force of res judicata and cannot be modified by courts through execution orders. The Court emphasized that contractual deadlines must be strictly observed under Article 1159 of the Civil Code, rejecting the lower courts' equity-based approach that excused the delay. The late delivery constituted breach warranting enforcement of the forfeiture clause rather than judicial modification of the agreement's terms.