Short answer. Possibly, yes. When a compromise covers only one specific thing, and newly-discovered documents show the party who received it under the settlement had no right to it, the Civil Code allows the compromise to be annulled or rescinded on that ground alone.
What the law says
But the compromise may be annulled or rescinded if it refers only to one thing to which one of the parties has no right, as shown by the newly-discovered documents.
Civil Code, Article 2039 — Concealed Documents. Read the full provision →
Two very different situations under one article
Article 2039 draws a sharp line between a general compromise and a compromise over a single thing. If parties settle all their differences generally and later find documents touching just one or a few of the many questions they resolved, that discovery alone does not undo the settlement — the general compromise stands. But when the settlement was never general to begin with, and instead concerned one specific item, the rule changes: newly-discovered documents showing one party had no right to that item can be a ground to annul or rescind the whole compromise.
Why a single-item settlement is treated differently
A settlement over many disputed points survives minor gaps in the parties' knowledge, because it reflects a broad give-and-take across several questions. A settlement over one thing has no such cushion — if it turns out the very right being compromised never belonged to the party who claimed it, the entire basis for the settlement collapses. That is why Article 2039 singles this situation out as annullable or rescissible, rather than leaving it under the general rule that mere discovery of documents does not disturb a compromise.
What the newly-discovered documents must show
The ground under this article is specific: the documents must be newly-discovered, and they must show that one of the parties had no right to the single thing the compromise was about. It is not enough that the documents are simply new or unfavorable — they have to go to the heart of who actually had the right being settled. If your compromise covered only that one item and the documents genuinely establish the other side never owned or held any right to it, that is the situation Article 2039 addresses directly.
What this does not cover
This article does not give a party a second chance simply because they regret the terms of a settlement, or because they later find documents that touch on side issues within a broader, general compromise — the first part of Article 2039 expressly protects that kind of settlement from being reopened. It also does not concern concealment by the other side, which is addressed separately; here the documents must be genuinely newly-discovered, not documents one party already had and chose to withhold. The remedy is narrow, tied to the one-thing, no-right situation the article describes.
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.
- Estate of Salud Jimenez vs. Philippine Export Processing Zone, G.R. No. 137285, January 16, 2001 — read the decision on LawPhil →
- Equitable PCI Banking Corporation vs. RCBC Capital Corporation, G.R. No. 182248, December 18, 2008 — read the decision on LawPhil →
- National Power Corporation vs. Hon. Rose Marie Alonzo-Legasto, et al, G.R. No. 148318, November 22, 2004 — read the decision on LawPhil →