G.R. No. L-27777 March 23, 1987
IN THE MATTER OF THE TESTATE ESTATE OF WILLIAM C. OGAN, Deceased NECITAS V. BINAMIRA, executrix-appellee, ISABELO V. BINAMIRA, claimant, vs. NECITAS OGAN-OCCENA, FEDERICO OGAN, NANCY OGAN GIBSON, LIBORIA OGAN GARCIA, oppositors-appellants.

FACTS

William C. Ogan died, leaving a will that instituted his natural children as heirs and designated Necitas Ogan Occena and Atty. Isabelo V. Binamira as co-executors. During the estate settlement, Binamira, who also served as a special administrator, filed substantial monetary claims against the estate for alleged past services. To expedite proceedings, the heirs and the executrix entered into a compromise agreement with Binamira and other claimants on October 27, 1965. The court approved this agreement. Pursuant to it, Binamira acknowledged receipt of a specific sum as full payment for his claims and fees, and his resignation as co-executor was confirmed.
Subsequently, Binamira filed a motion seeking additional compensation for services allegedly rendered after the date of the compromise agreement, from October 27, 1965, to January 14, 1966. The heirs and executrix opposed, arguing the claim was barred by the final compromise. The probate court granted Binamira’s motion for additional fees. The heirs appealed.

ISSUE

Whether the compromise agreement bars Atty. Binamira’s claim for additional compensation for services rendered after its execution.

RULING

Yes, the compromise agreement is a bar. The Supreme Court reversed the probate court’s orders. A compromise agreement, once approved by the court, has the force of res judicata and is conclusive upon the parties. Binamira, by acknowledging receipt of payment as “full payment” of his claims under the agreement and by having his resignation as co-executor confirmed based on that agreement, is estopped from contesting its finality. He cannot subsequently assert a right inconsistent with the terms he voluntarily accepted.
The legal logic is twofold. First, the claim for services rendered after the compromise is not allowable as a legitimate expense under the exception for costs of administration incurred up to the agreement’s approval. The timeframe of his new claim falls outside this period. Second, while a co-executor has a continuing duty to render accounts until the estate is fully settled, this duty is an obligation imposed by law (Rule 85, Section 8 of the Revised Rules of Court) and not a service warranting additional compensation when a final settlement of all claims has already been executed. The performance of this residual duty does not nullify the finality of the compromise regarding monetary claims. Therefore, the lower court acted without jurisdiction in granting the additional award.