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G.R. No. 174835 March 22, 2010
Facts: The decedent left an estate in which the heirs executed a compromise agreement to partition the
estate for themselves. However, the refusal by the petitioner to give the right of way and threatened to
build a concrete structure to prevent access against the respondent is the cause of the controversy
Issue: Can a Probate Court rule on the compromise agreement?
Held: A compromise is a contract whereby the parties, by making reciprocal concessions, avoid litigation
or put an end to one already commenced. Once submitted to the court and stamped with judicial approval,
it becomes more than a mere private contract binding upon the parties; having the sanction of the court
and entered as its determination of the controversy, it has the force and effect of any judgment.
Consequently, a judgment rendered in accordance with a compromise agreement is immediately
executory as there is no appeal from such judgment. When both parties enter into an agreement to end a
pending litigation and request that a decision be rendered approving said agreement, such action
constitutes an implied waiver of the right to appeal against the said decision.
In this instance, the case filed with the RTC was a special proceeding for the settlement of the estate of
Lourdes. The RTC therefore took cognizance of the case as a probate court.
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. It approves contracts entered into
for and on behalf 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 on September 13, 2000, the settlement
of the estate proceeding came to an end.