- Petitioner
- Benjamin Coronel
- Respondent
- Florentino Constantino
- Citation
- G.R. No. 121069
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Austria-Martinez, J.
- Decided
- February 7, 2003
Summary
This Supreme Court case involved a property dispute over co-owned land inherited from Honoria Aguinaldo. Respondents claimed ownership through a chain of sales starting with Emilia Coronel's execution of a deed of sale in 1981. The key legal issue was whether Emilia could validly sell the entire property or only her share, and whether her sons ratified the unauthorized sale through silence. The Supreme Court ruled that under Article 493 of the Civil Code, Emilia could only sell her own share as a co-owner. The Court found no ratification by her sons, as there was insufficient evidence they knew of the sale. The decision clarified co-ownership rights and established that Santos/Bernardo (and subsequently Constantino/Buensuceso) only acquired Emilia's portion, while Benjamin and the heirs of the deceased sons retained their respective shares, subject to future partition proceedings.
Intellegal Wiki · Key Holding
Affirmed with modification, holding that under Article 493 of the Civil Code a co-owner may validly sell only her own undivided share, and finding no ratification of the sale by the other co-owners absent evidence they knew of it and chose to remain silent.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.