Short answer. A compromise agreement is a contract where the parties make reciprocal concessions to avoid a lawsuit altogether or end one that has already started. Article 2028 defines it around that mutual give-and-take — each side gives up something to reach a settlement, rather than one side simply surrendering to the other's demands.
What the law says
A compromise is a contract whereby the parties, by making reciprocal concessions, avoid a litigation or put an end to one already commenced.
Civil Code, Article 2028 — Compromise Defined. Read the full provision →
The core requirement: reciprocal concessions
Article 2028 defines a compromise as a contract where the parties act by making reciprocal concessions. That word "reciprocal" is doing real work — a compromise requires both sides to give up something, even if not equally. An arrangement where one party simply gets everything he originally demanded and the other gets nothing in return is not the kind of mutual concession this article describes, whatever else it might be called.
Two different moments a compromise can address
The article covers two distinct situations: the parties may use a compromise to avoid a litigation before any case has been filed, or to put an end to one already commenced after a lawsuit is already underway. Either way, the mechanism is the same contract — reciprocal concessions — just applied at a different stage of the same underlying dispute.
How a compromise actually ends a pending lawsuit
When the parties compromise a case that has already been filed, the agreement itself is what resolves the underlying dispute between them; the lawsuit no longer has a live controversy to decide once both sides have accepted their respective concessions. This is why a compromise is often the mechanism behind a case being terminated without a full trial on the merits — the parties have replaced the court's eventual judgment with their own negotiated resolution.
Why it is treated as a contract, not just a settlement gesture
Because Article 2028 defines a compromise as a contract, it is bound by the ordinary requirements a contract needs to be valid — consent, a proper object, and a lawful cause among them — not merely by whatever informal understanding the parties may have reached. Treating it as a contract also means a party who later regrets the concessions he made cannot simply walk away from it the way he might abandon an informal promise; the compromise carries the same binding force any other valid contract does.
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.
- 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 →
- Ramon Jacinto vs. Atty. Benedict Litonjua and Atty. Jose Ma. Rosendo A. Solis, G.R. No. 207675, January 20, 2021 — read the decision on LawPhil →
- Fil-Estate Properties, Inc. vs. Paulino Reyes, et al, G.R. No. 152797, September 18, 2019 — read the decision on LawPhil →
- Republic of the Philippines Represented By DPWH vs. Heirs of Eligio Cruz Represented By Crisanta Oliquino & Heirs of Eligio Cruz Represented By Maximo Agalabia, G.R. No. 208956, October 17, 2018 — read the decision on LawPhil →