FACTS:

In the present case, thousands of banana plantation workers from over 14 countries filed class suits for damages in the United States in 1993 against 11 foreign corporations, alleging that exposure to the pesticide dibromochloropropane (DBCP) from the 1970s to the 1990s resulted in severe injuries to their reproductive systems. The U.S. courts dismissed the suits on the ground of forum non conveniens and directed the claimants to file in their home countries. Subsequently, 1,843 Filipino claimants filed a complaint in the Philippines against these corporations. Before pre-trial, certain defendants, including Chiquita Brands, Dow Chemical, Occidental Chemical, Shell Oil, and Del Monte, entered into a worldwide settlement through a "Compromise Settlement, Indemnity, and Hold Harmless Agreement." This agreement required the settlement amount to be deposited into an escrow account, which a mediator would administer for distribution to the claimants. The agreements were judicially approved by Judge Jesus L. Grageda, leading to the dismissal of the case except for certain conditions on future actions between remaining parties and counter-claims among defendants.

After the case dismissal, some claimants, represented by Atty. Macadangdang, moved for the execution of the judgment. The defendant corporations opposed this, asserting that the settlement amounts had been deposited into an escrow account, fulfilling their obligations, and that individual quitclaims signed by the claimants acknowledged receiving their shares. Despite this, the Regional Trial Court granted the motion for execution, finding no proof that the settlement amounts were delivered to each claimant. Consequently, a Writ of Execution was issued, directing the collection of specified sums from the defendants. Multiple motions and orders followed, including a dismissal of an order to amend the writ to include subsidiaries of the defendant corporations and a suspension of the writ’s implementation. Proceedings also took place at the Philippine Consulate in San Francisco, with later disputes over the validity of such jurisdictional actions further complicating the enforcement and evidence issues in the case.

ISSUES:

1. Whether the trial court’s issuance of a Writ of Execution and subsequent orders were issued with grave abuse of discretion.

2. Whether the petitioners’ subsidiaries and affiliates can be held solidarily liable under the Compromise Agreement.

RULING:

1. The Writ of Execution ordering the collection of the settlement amount directly from the petitioners was declared void as it varied the obligations under the Compromise Agreement, which only required depositing the settlement amount into an escrow account, not direct payment to the claimants.

2. The trial court gravely abused its discretion by holding the petitioners’ subsidiaries and affiliates solidarily liable. The Compromise Agreement did not explicitly impose solidary liability on these entities and there was no basis to pierce the corporate veil.

PRINCIPLES:

1. Doctrine of Immutability of Judgments: A judicially approved compromise agreement, which has the force of a final judgment, cannot be altered or modified by the courts.

2. Scope of Writ of Execution: A writ of execution must conform to the terms of the judgment it seeks to enforce and cannot alter or exceed these terms.

3. Solidary Liability in Philippine Law: Solidary liability must be clearly expressed in an agreement, or required by law or the nature of the obligation.

4. Piercing the Corporate Veil: This legal doctrine is not applicable without evidence showing that the corporate entity was misused to evade obligations.