Spouses Serafin Si v. Court of Appeals

Summary

This case involved a dispute over whether spouses Jose Armada could exercise the right of redemption when co-owner Crisostomo Armada sold his share of a 340 square meter lot in Pasay City to spouses Si. The Supreme Court ruled that no co-ownership existed because the original owner Escolastica had already partitioned the property through three separate deeds of sale in 1954, giving each son a concretely determined and separately identifiable portion. The Court held that once physical division occurs, the community ownership terminates and the right of redemption under Article 1623 of the Civil Code no longer applies. Additionally, the Court found that Jose had actual notice of the sale through his own correspondence, making formal written notice unnecessary. The decision clarifies that co-ownership requires undivided interests, not merely common titling.