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    Rodriguez v. Alikpala

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    AronJames
    The document summarizes a Supreme Court case regarding jurisdiction over parties. It finds that the city court had acquired jurisdiction over the Tolentinos, who were not originally parties but voluntarily participated in the defense by signing a compromise agreement with the plaintiffs to suspend an attachment on their daughter's store in exchange for assuming joint liability. While not formal parties, the Tolentinos willingly entered the compromise that became the basis of the city court's judgment and are therefore estopped from denying the court's authority and subject to its ruling.

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    Rodriguez v. Alikpala

    Uploaded by

    AronJames
    265 views1 page
    The document summarizes a Supreme Court case regarding jurisdiction over parties. It finds that the city court had acquired jurisdiction over the Tolentinos, who were not originally parties but voluntarily participated in the defense by signing a compromise agreement with the plaintiffs to suspend an attachment on their daughter's store in exchange for assuming joint liability. While not formal parties, the Tolentinos willingly entered the compromise that became the basis of the city court's judgment and are therefore estopped from denying the court's authority and subject to its ruling.

    Original Title

    04. Rodriguez v. Alikpala

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    The document summarizes a Supreme Court case regarding jurisdiction over parties. It finds that the city court had acquired jurisdiction over the Tolentinos, who were not originally parties but voluntarily participated in the defense by signing a compromise agreement with the plaintiffs to suspend an attachment on their daughter's store in exchange for assuming joint liability. While not formal parties, the Tolentinos willingly entered the compromise that became the basis of the city court's judgment and are therefore estopped from denying the court's authority and subject to its ruling.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    265 views1 page

    Rodriguez v. Alikpala

    Uploaded by

    AronJames
    The document summarizes a Supreme Court case regarding jurisdiction over parties. It finds that the city court had acquired jurisdiction over the Tolentinos, who were not originally parties but voluntarily participated in the defense by signing a compromise agreement with the plaintiffs to suspend an attachment on their daughter's store in exchange for assuming joint liability. While not formal parties, the Tolentinos willingly entered the compromise that became the basis of the city court's judgment and are therefore estopped from denying the court's authority and subject to its ruling.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
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    of 1

    Jurisdiction over the Parties

    04. Belen Rodriguez and Jose Santos, Jr v. Hon. Federico Alikpala (G.R. No. L-38314, June 25, 1974)

    KEY TAKE-AWAY OR DOCTRINE TO REMEMBER

    Jurisdiction over a person not formally or originally a party to a litigation may nevertheless be acquired, under proper conditions,
    thru the voluntary appearance of that person before the court. Thus, judgment may be directed against one who, although not a
    formal party in the case, has assumed or participated in the defense.

    FACTS

    • On August 19, 1971 the petitioner Rodriguez, assisted by her counsel, the petitioner Santos, filed an action with the city
    court of Manila against the spouses Manuel and Fe Rebollado for recovery of the sum of P5,320 plus interest, attorney's
    fees and costs. A writ of preliminary attachment was issued and served on the Rebollados at their store in Divisoria market.

    • Fe Rebollado to plead for time before the attachment was to be effectively enforced. Rodriguez agreed to cause the
    suspension of the attachment writ on condition that Fe Rebollado's parents, the now respondents Federico and Felisa
    Tolentino, would bind themselves, jointly and severally with the Rebollados, to pay the entire obligation subject of the suit.
    Felisa Tolentino who was then present agreed to this proposal ,and so the petitioner Santos, at the request of the petitioner
    Rodriguez, drew up a motion for judgment on a compromise embodying the terms of the agreement of the parties.

    • The Rebollados subsequently failed to comply with the terms of the compromise, thus prompting the petitioner Rodriguez
    to ask the city court for a writ of execution not only against the Rebollados but as well against the Tolentinos.

    • In excluding the Tolentinos from the effects of the judgment on a compromise rendered by the city court, the respondent
    court invokes two reasons: first, the dispositive portion of the judgment quoted above cannot be executed because it does
    not explicitly enjoin the Tolentinos to pay, jointly and severally with the Rebollados, the amount due to the plaintiff; and
    second, the city court never acquired jurisdiction over the persons of the Tolentinos and, therefore, the latter cannot be
    bound by the judgment rendered in civil case 204601.

    ISSUE/S STATUTES/ARTICLES INVOLVED

    Whether or not city court has acquired jurisdiction over the


    persons of the Tolentinos.

    HELD: YES

    There is no question in the mind of the respondent court that the Rebollados and the Tolentinos freely and voluntarily entered into
    the compromise agreement which became the basis of the judgment of the city court. Be it remembered that neither the Rebollados
    nor the Tolentinos question the existence of the indebtedness of the Rebollados or the amount thereof. The respondent court
    analyzed the evidence at length and found that the involvement of the Tolentinos in the compromise agreement arose out of their
    natural filial concern for their daughter Fe whose inventories at Divisoria market were under imminent threat of levy and seizure.
    The respondent court, moreover, brooks no doubt, and we concur with it, that both the Rebollados and the Tolentinos understood
    the plain unequivocal terms of the compromise agreement. And by assuming the roles of co-movants in the motion for a judgment
    on a compromise, the Tolentinos actively instigated the city court into giving its judicial imprimatur to the said agreement as well
    as their participation therein. Under the circumstances, the Tolentinos are estopped from denying the very authority they have
    invoked. Moreover, because they signed and executed the compromise agreement willingly and voluntarily, and, in a manner of
    speaking, with their eyes wide open, they should be bound by its terms. A person cannot, to paraphrase Justice Alejo Labrador,
    repudiate the effects of his voluntary acts simply because they do not. suit him. In thevery words of Justice Labrador, "in a regime
    of law and order, repudiation of an agreement validly entered into cannot be made without any ground or reason in law or in fact
    for such repudiation."

    And even if we assume that estoppel does not apply in this case, we nonetheless cannot shunt aside the principle of equity that
    jurisdiction over a person not formally or originally a party to a litigation may nevertheless be acquired, under proper conditions,
    thru the voluntary appearance of that person before the court. Thus, judgment may be directed against one who, although not a
    formal party in the case, has assumed or participated in the defense. By coming forward with the original litigants in moving for a
    judgment on a compromise and, furthermore, by assuming such interest in the final adjudication of the case as would place them
    in unequivocal liability, together with the Rebollados, to the plaintiff therein, the Tolentinos effectively submitted themselves to
    the jurisdiction of the city court. They were and are thus subject to its judgment.

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