Short answer. Generally no. Article 2037 says a compromise has upon the parties the effect and authority of res judicata. A validly settled claim is treated as already finally decided between you, so the other side cannot simply sue you again on the very same claim. There shall be no execution, though, except in compliance with a judicial compromise.
What the law says
A compromise has upon the parties the effect and authority of res judicata; but there shall be no execution except in compliance with a judicial compromise.
Civil Code, Article 2037 — Compromise Has Effect of Res Judicata. Read the full provision →
A compromise has the force of res judicata
Article 2037 gives a settlement real teeth: A compromise has upon the parties the effect and authority of res judicata. Res judicata means a matter already finally adjudged — one that cannot be litigated again between the same parties. So when you signed the compromise, the claim you settled was, in law, as good as finally decided. The other side cannot ordinarily reopen it by filing a fresh suit on the same claim; your compromise stands as a bar. This is the whole point of settling: to put the dispute to rest with the same finality a judgment would have.
What a compromise bars
Because the compromise carries the authority of res judicata, it forecloses relitigation of what the parties settled. If the other side sues you again on the very claim covered by the agreement, you can raise the compromise as a defense to have the new action dismissed — the matter has already been laid to rest between you. This protects you from being made to fight the same battle twice, which is exactly the mischief res judicata prevents. The finality attaches to the parties to the compromise; it is their dispute that the settlement conclusively resolves.
Judicial versus extrajudicial compromise
The article draws one practical line: there shall be no execution except in compliance with a judicial compromise. A judicial compromise — one approved by the court in a case — can be enforced by execution, like a judgment, if the other side fails to comply. An extrajudicial compromise, made out of court, still has the binding effect and authority of res judicata between the parties, but you cannot go straight to execution on it; enforcing it generally requires bringing an action on the agreement. So both kinds bind, but only the court-approved compromise comes with the immediate machinery of execution.
When a compromise might not protect you
The bar assumes a valid, existing compromise that actually covers the claim now being sued upon. It does not shield the other side's suit if the compromise is void or was successfully annulled — for instance on grounds that vitiate consent — or if the new claim is genuinely different from what you settled. Nor does the article stop enforcement of the compromise itself if you are the one who failed to honour it. Read carefully, then: a valid compromise generally prevents a second suit on the same settled claim, but its protection is only as solid as the agreement behind it.
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.
- Central Cement Corp. vs. Mines Adjudication Board, et al, G.R. No. 173562, January 22, 2008 — read the decision on LawPhil →
- Margarita M. Benedicto-Muñoz vs Maria Angeles Cacho-Olivares, et al./Abacus Securities Corporation and Joel Chua Chui vs Maria Angeles Cacho-Olivares, et al./Sapphire Securities, Inc. vs Maria Angeles Cacho-Olivares, et al, G.R. No. 179121 / G.R. No. 179128 / G.R. No. 179129, November 9, 2015 — read the decision on LawPhil →
- Nestor T. Gadrinab vs. Nora T. Salamanca, Antonio Talao, and Elena Lopez, G.R. No. 194560, June 11, 2014 — read the decision on LawPhil →
- Rey Castigador Catedrilla vs. Mario and Margie Lauron, G.R. No. 179011, April 15, 2013 — read the decision on LawPhil →