G.R. No. L-33141 July 6, 1973
SARBRO & COMPANY, INC., plaintiff-appellee, vs. BRIGIDA VILLANUEVA VDA. DE GARCHITORENA, and THE REGISTER OF DEEDS OF THE PROVINCE OF COTABATO, defendants, BRIGIDA VILLANUEVA VDA. DE GARCHITORENA, deceased, now substituted by DR. SENEN L. R. ASUAN in his capacity as Administrator of her Estate, defendant-appellant.

FACTS

This case originated from a dispute over a parcel of land in Cotabato covered by Transfer Certificate of Title No. 5214. Plaintiff-appellee Sarbro & Company, Inc. sought the registration of a Deed of Absolute Sale with Mortgage (Exhibit “F”) executed by the deceased Mariano Garchitorena in its favor. Defendant-appellant Brigida Villanueva Vda. de Garchitorena, representing conflicting interests in the property, opposed the registration. The Court of First Instance of Cotabato decided in favor of Sarbro & Company, prompting an appeal to the Court of Appeals, which certified the case to the Supreme Court as it involved purely questions of law.
While the case was pending before the Supreme Court, the parties reached an amicable settlement. The Estate of Brigida V. Vda. de Garchitorena, represented by its court-appointed administrator Dr. Senen L.R. Asuan, and Sarbro & Company, Inc., executed a Compromise Agreement dated August 21, 1972. In consideration of the sum of Ten Thousand Pesos (P10,000.00), the Estate relinquished all its claims over the subject land in favor of Sarbro & Company. This agreement was subsequently submitted to and approved by the Court of First Instance of Manila, which had jurisdiction over the Estate’s intestate proceedings.

ISSUE

Whether the Supreme Court should approve the Compromise Agreement submitted by the parties and render judgment based on its terms.

RULING

Yes. The Supreme Court approved the Compromise Agreement and rendered judgment in accordance with its terms. The legal logic is anchored on the fundamental principle favoring the amicable settlement of disputes. Compromise agreements are highly favored in law and jurisprudence as they secure the ends of justice and promote speedy litigation. For a compromise to be judicially approved, it must not be contrary to law, morals, good customs, public order, or public policy.
The Court meticulously examined the submitted Joint Motion and the attached Compromise Agreement. It found the agreement to be in order, having been voluntarily executed by the duly authorized representatives of both parties—the administrator of the Estate and the president of the corporation. Crucially, the agreement had already received the requisite approval from the probate court (the Court of First Instance of Manila) overseeing the Estate, which validated the administrator’s authority to enter into such a settlement on behalf of the heirs and creditors. Finding no legal infirmity, the Court upheld the agreement. Consequently, it ordered the dismissal of the appeal and directed the Register of Deeds of Cotabato to accept and register the Deed of Absolute Sale with Mortgage (Exhibit “F”), thereby finally resolving the controversy.