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.

Statutes applied

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By Intellegal Editorial Board · February 7, 2003

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