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ANITA REYES-MESUGAS v. ALEJANDRO AQUINO REYES

FACTS:

Petitioner and respondent are siblings and heirs of Lourdes Aquino Reyes. Lourdes died intestate, leaving three parcels of land. On February 3, 2000, respondent filed a petition for settlement of Lourdes' estate, seeking his appointment as administrator. Petitioner and their father, Pedro, opposed the petition. On August 30, 2000, a compromise agreement was entered into, partitioning the estate. A decision was rendered by the RTC based on the compromise agreement. Petitioner filed a motion to cancel a notice of lis pendens annotation on one of the parcels of land. Respondent opposed it, claiming that there were "side agreements" that had yet to be fulfilled. The RTC denied the motion to cancel the notice of lis pendens annotation. Petitioner appealed to the Court.

ISSUES:

  1. Whether the notice of lis pendens on TCT No. 24475 should be cancelled despite respondent's claim of an unfulfilled "side agreement".

RULING:

  1. The notice of lis pendens should be cancelled. The settlement of the estate proceeding had terminated with the RTC’s approval of the compromise agreement, rendering the annotation of lis pendens unnecessary. The alleged side agreement on the right of way was outside the jurisdiction of the probate court and any issues arising from it can be addressed through an ordinary action for specific performance in a court of general jurisdiction. The cancellation is further reinforced by Section 77 of PD No. 1529 and Section 4, Rule 90 of the Rules of Court, which dictate that the notice of lis pendens was deemed cancelled upon the registration of the court's final judgment related to the property.

PRINCIPLES:

  1. A compromise agreement once judicially approved becomes final and executory and binds the parties.

  2. Probate courts have limited jurisdiction confined to matters relating to the settlement of estates, and cannot adjudicate personal or contractual rights between heirs.

  3. Section 4, Rule 90 of the Rules of Court mandates the recording of final orders and judgments relating to the partition of real estate in the registry of deeds.

  4. Section 77 of PD No. 1529 provides that a notice of lis pendens is deemed cancelled upon the registration of a final judgment or other disposition terminating the plaintiff's rights in the property.