Chiquita Brands Inc Vs Omelio

Doctrine:
A compromise that has received judicial imprimatur "becomes more than a

mere contract. A judicial compromise is regarded as a "determination of the
controversy" between the parties and "has the force and effect of [a final]
judgment. “In other words, it is both a contract and "a judgment on the merits. “It
may neither be disturbed nor set aside except in cases where there is forgery or
when either of the parties' consent has been vitiated.
Case Title:
CHIQUITA BRANDS, INC. and CHIQUITA BRANDS INTERNATIONAL,
INC., Petitioners vs. HON. GEORGE E. OMELIO, REGIONAL TRIAL COURT,
DAVAO CITY, BRANCH 14, SHERIFF ROBERTO C. ESGUERRA, CECILIO G.
ABENION, and 1,842 OTHER PLAINTIFFS IN CIVIL CASE NO. 95-45,
Respondents G.R. No. 189102 June 7, 2017 (LEONEN, J. :)
Facts:
Thousands of banana plantation workers from over 14 countries instituted
class suits for damages in the United States against 11 foreign corporations
namely: (1) Shell Oil Company; (2) Dow Chemical Company; (3) Occidental
Chemical Corporation; (4) Standard Fruit Company; (5) Standard Fruit and
Steamship Co.; (6) Dole Food Company, Inc.; (7) Dole Fresh Fruit Company; (8)
Chiquita Brands, Inc.; (9) Chiquita Brands International, Inc.; (10) Del Monte Fresh
Produce, N.A.; and (11) Del Monte Tropical Fruit Co.
The banana plantation workers claimed to have been exposed to
dibromochloropropane (DBCP) in the 1970s up to the 1990s while working in
plantations that utilized it. As a result, these workers suffered serious and
permanent injuries to their reproductive systems.
The United States courts dismissed the actions on the ground of forum non
conveniens and directed the claimants to file actions in their respective home
countries.
On May 3, 1996, 1,843 Filipino claimants filed a complaint for damages
against the same foreign corporations before the Regional Trial Court in Panabo
City, Davao del Norte, Philippines and was docketed as Civil Case No. 95-45.
Before pre-trial, Chiquita Brands, Inc., Chiquita Brands International, Inc.
(collectively, Chiquita), Dow Chemical Company (Dow), Occidental Chemical
Corporation (Occidental), Shell Oil Company (Shell), Del Monte Fresh Produce,
N.A., and Del Monte Tropical Fruit Co. (collectively, Del Monte) entered into a
worldwide settlement in the United States with all the banana plantation workers.
The parties executed a document denominated as the "Compromise Settlement,
Indemnity, and Hold Harmless Agreement" (Compromise Agreement).The
Filipino claimants were represented by their counsel, Atty. Renato Ma. Callanta
(Atty. Callanta).
The Compromise Agreement provided, among others, that the settlement
amount should be deposited in an escrow account, which should be administered
by a mediator. After the claimants execute individual releases, the mediator shall
give the checks representing the settlement amounts to the claimants' counsel, who
shall then distribute the checks to each claimant.
Consequently, Chiquita, Dow, Occidental, Shell, and Del Monte moved to
dismiss Civil Case No. 95-45.In support of its Motion for Partial Dismissal,
Chiquita alleged that all claimants, except James Bagas and Dante Bautista,
executed quitclaims denominated as "Release in Full." Chiquita attached five (5)
quitclaims in its motion.
The Regional Trial Court, Panabo City approved the Compromise
Agreement by way of judgment on compromise. Accordingly, it dismissed Civil
Case No. 95-45.
Shortly after the dismissal of Civil Case No. 95-45, several claimants moved
for the execution of the judgment on compromise.
Chiquita, Dow, Occidental, Shell, and Del Monte opposed the execution on
the ground of mootness. They argued that they had already complied with their
obligation under the Compromise Agreement by depositing the settlement amounts
into an escrow account. Hence, there was nothing left for the court to execute.
The Regional Trial Court, Panabo City granted the Motion for Execution in
the Order dated April 15, and ordered specifically to collect or demand from
petitioners the amount provided in their Compromise Agreement.
Petitioners filed a Motion for Reconsideration, however, it was denied.
Hence, recourse to the SC through Certiorari.
Issue:
Whether Execution Order issued by the trial court ordering to collect or
demand from petitioners the amount provided in their Compromise Agreement is
valid.
Rulings:
No. Unlike an extrajudicial compromise, a compromise that has received
judicial imprimatur "becomes more than a mere contract." A judicial compromise
is regarded as a "determination of the controversy" between the parties and "has
the force and effect of [a final] judgment." In other words, it is both a contract and
"a judgment on the merits.”It may neither be disturbed nor set aside except in cases
where there is forgery or when either of the parties' consent has been vitiated.
Under the judicially approved Compromise Agreement, petitioners are
obliged to deposit the settlement amount in escrow within 10 business days after
they receive a signed Compromise Agreement from the counsel of the claimants.
There was nothing in the Compromise Agreement that required petitioners
to ensure the distribution of the settlement amount to each claimant. Petitioners'
obligation under the Compromise Agreement was limited to depositing the
settlement amount in escrow. On the other hand, the actual distribution of the
settlement amounts was delegated to the chosen mediator, Mr. Mills. To require
proof that the settlement amounts have been withdrawn and delivered to each
claimant would enlarge the obligation of petitioners under the Compromise
Agreement.
It must be remembered that the writ of execution derives its validity from the
judgment it seeks to enforce and must essentially conform to the judgment's terms.
It can neither be wider in scope nor exceed the judgment that gives it life.
Otherwise, it has no validity. Thus, in issuing writs of execution, courts must look
at the terms of the judgment sought to be enforced.

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Doctrine:

A compromise that has received judicial imprimatur "becomes more than a

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