Marcelino Tan v. Jose Renato Lim

Summary

This case involved two related disputes over a 488 sq.m. property inherited by two sides of the Briones family. The Supreme Court upheld the Court of Appeals' finding that an oral partition had validly terminated the co-ownership between the heirs of brothers Victoriano and Joaquin Briones. Key evidence included Flora Jovellanos' judicial admission that her group owned a specific portion while the other group owned the rest, and the fact that Flora's group alone leased exactly half the property to Marcelino Tan without the other co-owners' participation. The Court applied equity principles allowing enforcement of oral partitions that have been fully performed through actual possession and acts of ownership. The decision clarifies that oral partitions are valid contracts not requiring written form, and that judicial admissions are conclusive evidence. The injunction case was deemed moot due to lease expiration, and the legal redemption case failed because co-ownership had already been terminated by partition before the challenged sale occurred.