Short answer. Generally no. Article 2036 says a compromise covers only what is definitely stated in it, or what necessarily follows from its terms. Even a broadly worded general renunciation of rights is read narrowly — it reaches only the rights connected with the particular dispute the compromise settled, not unrelated claims.
What the law says
A compromise comprises only those objects which are definitely stated therein, or which by necessary implication from its terms should be deemed to have been included in the same. A general renunciation of rights is understood to refer only to those that are connected with the dispute which was the subject of the compromise.
Civil Code, Article 2036 — Scope of a Compromise. Read the full provision →
A compromise is measured by its object
A settlement does not silently swallow everything between the parties. Article 2036 fixes its reach by its stated purpose: A compromise comprises only those objects which are definitely stated therein, or which by necessary implication from its terms should be deemed to have been included in the same. Two things are covered — what the document actually names, and what its terms make unavoidable. A claim that is neither written into the agreement nor a necessary consequence of what was written stays outside it. The starting assumption, in other words, is that you gave up only what you addressed.
Sweeping waivers are read down
Many settlements end with broad language — a release of "any and all claims" the parties may have against one another. Article 2036 does not take that at face value: A general renunciation of rights is understood to refer only to those that are connected with the dispute which was the subject of the compromise. However expansive the wording, the law tethers it to the controversy the parties were actually resolving. A blanket release attached to the settlement of one dispute does not quietly extinguish rights arising from an entirely separate matter the parties never had in mind.
"Necessary implication" and "connected with the dispute"
Both limiting phrases are applied strictly. Necessary implication means the claim must follow inevitably from the settled terms, not merely be the sort of thing that could have been included. Connection to the dispute asks whether the right arises out of the same controversy that the compromise addressed. To illustrate the line: settling a claim for damage from a vehicular accident does not, without more, wipe out an unrelated debt one party owes the other, because that debt belongs to a different dispute. The subject the parties were fighting over is the boundary of what the release can touch.
Drafting to match your intention
The rule cuts both ways, so write to the result you want. If you genuinely mean to close out every account between you, do not rely on boilerplate — identify the specific claims and disputes you are releasing so they fall squarely within what is "definitely stated." If instead you want to keep a particular claim alive, make sure it lies outside the settled subject and, ideally, say expressly that it is reserved. Where the wording is ambiguous, the article's default protects the party resisting a broad waiver, so precision favours whoever is trying to extinguish claims.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Dana S. Santos vs. Leodegario R. Santos, G.R. No. 214593, July 17, 2019 — read the decision on LawPhil →
- Iligan Bay Mfg. Corp. et al vs. Henry Dy, G.R. No. 140836 / G.R. No. 140907, June 8, 2007 — read the decision on LawPhil →
- Filcon Manufacturing Corporation vs. Lakas Manggagawa sa Filcon-Lakas Manggagawa Labor Center (LMF-LMLC), G.R. No. 150166, July 26, 2004 — read the decision on LawPhil →