Primary Holding

The Supreme Court held that the notice of lis pendens should be cancelled pursuant to Section 77 of PD No. 1529 in relation to Section 4, Rule 90 of the Rules of Court, as the estate proceedings had been terminated by the court-approved compromise agreement.

Background

The case arose from the settlement of the estate of Lourdes Aquino Reyes. The property in question was covered by Transfer Certificate of Title (TCT) No. 24475, which had a notice of lis pendens annotated on it during the estate proceedings. After a compromise agreement was reached and approved by the court, the petitioner sought to cancel the lis pendens annotation, which the respondent opposed due to an alleged unfulfilled side agreement regarding a right of way.

Facts

• 1. Petitioner and respondent are siblings, children of Lourdes Aquino Reyes and Pedro N. Reyes
• 2. Lourdes died intestate, leaving three parcels of land including TCT No. 24475
• 3. A compromise agreement was reached dividing the estate
• 4. The agreement recognized improvements on TCT No. 24475 as belonging to Antonio Reyes and Anita Reyes-Mesugas
• 5. A side agreement allegedly granted respondent a one-meter right of way

Arguments of the Petitioners

• 1. Estate proceedings had terminated with the compromise agreement
• 2. Notice of lis pendens had served its purpose and should be cancelled
• 3. The probate court had no jurisdiction over side agreements

Arguments of the Respondents

• 1. Side agreements were yet to be fulfilled
• 2. Petitioner refused to grant agreed-upon right of way
• 3. Notice should remain until right of way is inscribed on title

Issues

• 1. Whether the notice of lis pendens should be cancelled after the approval of the compromise agreement in the estate proceedings

Ruling

• 1. The Supreme Court granted the petition and ordered the cancellation of the lis pendens annotation. The Court reasoned that once the compromise agreement was submitted to the court and received judicial approval, it became more than a mere private contract and had the force and effect of any judgment. The Court emphasized that the probate court's jurisdiction was limited to matters pertaining to the estate and did not extend to rights arising from separate contracts. Therefore, any side agreements regarding rights of way were outside the court's limited jurisdiction as a probate court. The Court further held that the approval of the compromise agreement effectively brought the intestate proceedings to a close, making the continued annotation of lis pendens unnecessary. When the September 13, 2000 decision was recorded in the Registry of Deeds pursuant to Section 4, Rule 90 of the Rules of Court, the notice of lis pendens was deemed cancelled by operation of law under Section 77 of PD No. 1529.

Doctrines

• 1. Compromise Agreement Effect: Becomes more than a private contract when court-approved; has force of judgment
• 2. Limited Jurisdiction of Probate Courts: Acts only on estate matters, not on property rights from contracts
• 3. Lis Pendens Cancellation: Proper when annotation no longer necessary to protect rights

Precedents Cited

• 1. Domingo v. Court of Appeals (1996): Established that compromise agreements are immediately executory
• 2. Pio Baretto Realty Dev., Inc. v. Court of Appeals (1984): Defined limited jurisdiction of probate courts
• 3. Santiesteban v. Santiesteban (1939): On termination of probate proceedings

Statutory and Constitutional Provisions

• 1. Presidential Decree No. 1529, Section 77: Cancellation of Lis Pendens
• 2. Rules of Court, Rule 90, Section 4: Recording partition orders
• 3. Civil Code, Article 2028: Definition of compromise
• 4. Rules of Court, Rule 89: Compromise agreements in estate proceedings