Reyes Mesuga V Reyes SAPNU D2017

Reyes-Mesugas v. Reyes (2010) 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
Petitioner: Anita Reyes-Mesugas arising from the contract. It approves contracts entered into for and on behalf
Respondent: Alejandro Aquino Reyes of the estate or the heirs to it but this is by fiat of the Rules of Court. It is
apparent therefore that when the RTC approved the compromise agreement,
DOCTRINE: Extent of jurisdiction of the probate court. Settled is the rule that the settlement of the estate proceeding came to an end.
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 Moreover, a notice of lis pendens may be cancelled when the annotation is
contract. It approves contracts entered into for and on behalf of the estate or not necessary to protect the title of the party who caused it to be recorded.
the heirs to it but this is by fiat of the Rules of Court. The compromise agreement did not mention the grant of a right of way to
respondent. Any agreement other than the judicially approved
FACTS: compromise agreement between the parties was outside the limited
1. Anita and Alejandro are children of Pedro and Lourdes Reyes. Lourdes jurisdiction of the probate court.
died intestate, leaving to her heirs, among others, three parcels of land.
More importantly, the order of the probate court approving the compromise
2. Alejandro filed a petition for the settlement of the estate of Lourdes, had the effect of directing the delivery of the residue of the estate of Lourdes
praying for his appointment as administrator due to alleged irregularities to the persons entitled thereto under the compromise agreement. As such, it
and fraudulent transactions by the other heirs. brought to a close the intestate proceedings and the probate court lost
jurisdiction over the case, except only as regards to the compliance and the
3. Anita, Pedro and Arturo (another siblng) opposed the petition. fulfillment by the parties of their respective obligations under the compromise
agreement.
4. A compromise agreement was entered into the parties whereby the
estate of Lourdes was partitioned. RTC approved said partition. Having established that the proceedings for the settlement of the estate of
Lourdes came to an end upon the RTCs promulgation of a decision based on
5. Anita filed a motion to cancel lis pendens (parcel of land to be shared by the compromise agreement, Section 4, Rule 90 of the Rules of Court
Anita and Alejandro) in view of the finality of judgment in the settlement provides:
of the estate.
Sec. 4. Recording the order of partition of estate. - Certified
6. Alejandro opposed; claiming that there are side agreements yet to be copies of final orders and judgments of the court relating to
fulfilled between them. One such agreement is the right of way which the real estate or the partition thereof shall be recorded in
Anita refueses to give. the registry of deeds of the province where the property is
situated.
7. RTC denied Anitas motion. MR also denied. In line with the recording of the order for the partition of the estate, paragraph
2, Section 77 of Presidential Decree (PD) No. 1529 [21] provides:
ISSUE: WON RTC as a probate court has jurisdiction over the issue of right
of way Section 77. Cancellation of Lis Pendens xxx xxx xxx
xxx xxx
RULING + RATIO: NONE At any time after final judgment in favor of the
defendant, or other disposition of the action such as to
A judgment rendered in accordance with a compromise agreement is terminate finally all rights of the plaintiff in and to the
immediately executory as there is no appeal from such judgment. When both land and/or buildings involved, in any case in which a
parties enter into an agreement to end a pending litigation and request that a memorandum or notice of lis pendens has been registered
decision be rendered approving said agreement, such action constitutes an as provided in the preceding section, the notice
implied waiver of the right to appeal against the said decision 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 notice of lis pendens inscribed on TCT No. 24475 was deemed cancelled by
disposal thereof. virtue of Section 77 of PD No. 1529.
Thus, when the September 13, 2000 decision was recorded in the Registry of
Deeds of Rizal pursuant to Section 4, Rule 90 of the Rules of Court, the

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Reyes-Mesugas v. Reyes (2010) Settled is the rule that a probate court is a tribunal of limited jurisdiction.

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