Short answer. Possibly. Article 2039 says that after a general compromise, merely discovering documents about some of the settled questions is not by itself a ground to undo it — unless the other party concealed them. Concealment changes the result, and the compromise may then be annulled or rescinded.
What the law says
When the parties compromise generally on all differences which they might have with each other, the discovery of documents referring to one or more but not to all of the questions settled shall not itself be a cause for annulment or rescission of the compromise, unless said documents have been concealed by one of the parties.
Civil Code, Article 2039 — Concealed Documents. Read the full provision →
A general compromise is meant to be final
When people settle all the differences between them, the value of the deal lies in its finality — neither side wants the matter reopened every time an old paper surfaces. Article 2039 protects that finality: When the parties compromise generally on all differences which they might have with each other, the discovery of documents referring to one or more but not to all of the questions settled shall not itself be a cause for annulment or rescission of the compromise. As a rule, then, finding evidence after the fact — however helpful it might have been earlier — is not enough on its own to unravel a settlement you entered into freely.
Concealment is what changes the answer
The article carries a decisive exception in its closing words: the discovery is no ground to undo the compromise "unless said documents have been concealed by one of the parties." It is the hiding, not the mere existence, of the papers that matters. A party who deliberately suppressed relevant documents and then obtained a settlement cannot keep the benefit of a bargain built on that suppression. So the real question in your situation is not simply that documents turned up, but whether the other side knew of them and withheld them from you while the compromise was being negotiated.
A second, narrower ground
Article 2039 also allows the compromise to be annulled or rescinded if it refers only to one thing to which one of the parties has no right, as shown by the newly-discovered documents. This is a tighter situation than a general settlement of many differences. Where the compromise concerned a single subject, and the fresh documents demonstrate that a party never had any right to that thing at all, the settlement can be undone even without proof of concealment, because it rested on a claim that did not exist. The two grounds address different defects and should not be conflated.
Concealment has to be shown
Practically, everything turns on separating "I found new evidence" from "they hid it." The first, standing alone, will not reopen a general compromise; the second can. If you intend to attack the settlement, be ready to show how and when you discovered the documents and what indicates they were in the other party's hands and withheld — correspondence, prior requests, their own records. The burden rests on the party seeking to set the compromise aside, so build the case for concealment carefully rather than relying on the significance of the documents themselves.
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 →