A notice of lis pendens annotated in connection with an estate settlement proceeding should be cancelled when the proceeding has terminated by virtue of a judicially approved compromise agreement, and the basis for its continued annotation is an alleged extraneous agreement that falls outside the limited jurisdiction of the probate court.

Petitioner Anita Reyes-Mesugas and respondent Alejandro A. Reyes are siblings and heirs of Lourdes Aquino Reyes, who died intestate leaving several properties, including a lot covered by TCT No. 24475. Respondent initiated proceedings for the settlement of Lourdes' estate, which eventually led to a compromise agreement partitioning the estate among the heirs.

• Petitioner Anita Reyes-Mesugas and respondent Alejandro A. Reyes are children of Lourdes Aquino Reyes, who died intestate.
• On February 3, 2000, respondent filed a petition for settlement of Lourdes' estate (SP No. M-4984) in the RTC of Makati, Branch 62, alleging irregularities by other heirs.
• On August 30, 2000, the parties entered into a compromise agreement partitioning the estate, including a lot covered by TCT No. 24475.
• The RTC rendered a decision on September 13, 2000, based on and approving the compromise agreement.
• On December 7, 2004, petitioner filed a motion to cancel the notice of lis pendens annotated on TCT No. 24475, arguing the estate settlement proceeding had terminated.
• Respondent opposed the motion, claiming an unfulfilled "side agreement" (not part of the judicially approved compromise) granting him a one-meter right of way on the lot covered by TCT No. 24475, and argued the lis pendens must remain until this right of way was inscribed on the title.
• The RTC, in its order dated January 26, 2006, denied the motion to cancel, stating that the petitioner was still bound by the right of way agreement and it should be complied with before cancellation.
• Petitioner's notice of appeal was denied by the RTC, and her subsequent motion for reconsideration was also denied.

• The settlement of the estate proceeding had terminated with the finality of the judgment based on the compromise agreement.
• The notice of lis pendens had served its purpose and could already be cancelled.
• The alleged "side agreement" concerning the right of way was not part of the judicially approved compromise agreement and was outside the jurisdiction of the probate court.

• The parties executed "side agreements" in addition to the compromise agreement, one of which granted respondent a one-meter right of way on the lot covered by TCT No. 24475.
• Petitioner refused to grant the right of way and threatened to build a concrete structure to prevent access.
• The notice of lis pendens on TCT No. 24475 must remain until petitioner permits the inscription of the right of way on the certificate of title.

• Whether the RTC erred in denying the petitioner's motion to cancel the notice of lis pendens annotated on TCT No. 24475.

• Yes, the RTC erred in denying the motion to cancel the notice of lis pendens.
• The Supreme Court held that a probate court is a tribunal of limited jurisdiction and acts on matters pertaining to the estate but not on rights to property arising from contracts extraneous to the estate settlement, such as the alleged "side agreement" for a right of way.
• When the RTC approved the compromise agreement on September 13, 2000, the settlement of the estate proceeding came to an end.
• The compromise agreement did not mention the grant of a right of way to the respondent; any agreement other than the judicially approved compromise was outside the limited jurisdiction of the probate court.
• Therefore, there was no reason for the RTC, acting as a probate court, not to cancel the notice of lis pendens, as the respondent had no right arising from the probate proceedings that needed protection by the lis pendens regarding the "side agreement."
• Any alleged right arising from the "side agreement" on the right of way can be protected by filing an ordinary action for specific performance in a court of general jurisdiction.
• The order of the probate court approving the compromise had the effect of directing delivery of the estate residue, bringing the intestate proceedings to a close and causing the probate court to lose jurisdiction, except for compliance with the compromise agreement itself.
• Pursuant to Section 77 of PD No. 1529, when the September 13, 2000 decision (based on the compromise) was recorded, the notice of lis pendens was deemed cancelled.

• Limited Jurisdiction of Probate Courts — A probate court's authority is confined to matters related to the settlement of the deceased's estate, such as the administration, liquidation, and distribution of assets. It generally cannot adjudicate claims of title to property or rights arising from contracts independent of the estate settlement. Applied here, the Court stated the RTC, as a probate court, had no jurisdiction over the alleged "side agreement" for a right of way, as it was not part of the judicially approved compromise agreement concerning the estate.
• Compromise Agreement (Effect of Judicial Approval) — A compromise is a contract where parties make reciprocal concessions to avoid or end litigation. Once judicially approved, it becomes more than a private contract; it has the force and effect of a judgment and is immediately executory. Applied here, the judicially approved compromise agreement ended the estate settlement proceeding, and its terms were the only ones enforceable by the probate court.
• Lis Pendens (Purpose and Cancellation) — A notice of lis pendens serves to protect the rights of the party who caused its annotation by warning prospective buyers or encumbrancers that the property is in litigation. It may be cancelled when the annotation is not necessary to protect the title of the party who caused it to be recorded, or when the case is finally disposed of. Applied here, since the estate proceeding was terminated by the compromise agreement and the "side agreement" was outside the probate court's jurisdiction, the lis pendens was no longer necessary to protect any right of the respondent within that specific proceeding.
• Termination of Special Proceedings (Estate Settlement) — The order of the probate court approving a compromise agreement and directing the delivery of the estate's residue to the entitled persons under said agreement brings the intestate proceedings to a close. Applied here, the RTC's approval of the compromise ended the estate settlement, divesting the probate court of jurisdiction over matters not covered by the compromise, including the alleged "side agreement."

• "Settled is the rule that a probate court is a tribunal of limited jurisdiction. It acts on matters pertaining to the estate but never on the rights to property arising from the contract."
• "Moreover, a notice of lis pendens may be cancelled when the annotation is not necessary to protect the title of the party who caused it to be recorded."
• "At any time after final judgment in favor of the defendant, or other disposition of the action such as to terminate finally all rights of the plaintiff in and to the land and/or buildings involved, in any case in which a memorandum or notice of lis pendens has been registered as provided in the preceding section, the notice of lis pendens shall be deemed cancelled upon the registration of a certificate of the clerk of court in which the action or proceeding was pending stating the manner of disposal thereof." (Quoting PD 1529, Sec. 77)

• Domingo v. Court of Appeals, 325 Phil. 469 (1996) — Cited to support the principle that a judgment rendered in accordance with a compromise agreement is immediately executory and implies a waiver of the right to appeal against said decision.
• Pio Baretto Realty Dev., Inc. v. Court of Appeals, No. L-62432, 3 August 1984, 131 SCRA 606 — Referenced to establish the rule that a probate court is a tribunal of limited jurisdiction and acts on matters pertaining to the estate but not on rights to property arising from contract.
• Santiesteban v. Santiesteban, 68 Phil. 367 (1939); Philippine Commercial and Industrial Bank v. Escolin, G.R. No. L-27860, 29 March 1974, 50 SCRA 266 — Cited to support the point that the order of the probate court approving the compromise had the effect of directing the delivery of the residue of the estate, thereby bringing the intestate proceedings to a close.

• Rule 90, Section 4, Rules of Court (Recording the order of partition of estate) — States that certified copies of final orders and judgments of the court relating to real estate or its partition shall be recorded in the registry of deeds. Relevant because the recording of the final order based on the compromise agreement signaled the termination of the estate proceedings concerning the property.
• Presidential Decree (PD) No. 1529, Section 77 (Cancellation of Lis Pendens) — Provides that a notice of lis pendens shall be deemed cancelled upon the registration of a certificate of the clerk of court stating the manner of disposal of the action, particularly after a final judgment or other disposition terminating all rights of the plaintiff. This section was directly applied to rule that the lis pendens was deemed cancelled upon the recording of the RTC's decision based on the compromise agreement.
• Article 2028, New Civil Code (Compromise Agreement) — Defines a compromise as a contract whereby parties, by making reciprocal concessions, avoid litigation or end one already commenced. Relevant as the basis for the nature of the agreement that terminated the estate proceedings.
• Rule 13, Section 14, Rules of Court (Lis Pendens) — (Impliedly, though text refers to it as Sec. 19 in a footnote, likely related to the general rules on lis pendens). Relevant as the procedural basis for the annotation and cancellation of lis pendens.
• Rule 89, Rules of Court — Mentioned in relation to the probate court's power to approve contracts entered into for and on behalf of the estate.