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The Supreme Court ruled that the petitioners were not required to aver that earnest efforts toward compromise were made pursuant to Article 151 of the Family Code. [1] Article 151 does not apply to cases that cannot be subject to compromise, such as those involving future legitime. [2] Moreover, the failure to allege compromise efforts is a waivable defect, not a jurisdictional one. [3] Since no motion to dismiss was filed on this basis and the defense was not raised on appeal, it is deemed waived.

Author

Portia Wynona

Language

EN