Rizalino v. Paraiso Development Corporation

Summary

This case involves a Contract to Sell between six of eight co-heir siblings and Paraiso Development Corporation for two agricultural parcels in Cavite. The Supreme Court upheld the contract's validity, ruling that while the signatures of five co-heirs did not create agency authority under Article 1874 requiring written authorization for land sales through agents, they were directly bound as signatories in their own right. The Court rejected arguments that their consent was conditional on unanimous approval from all eight heirs, finding that co-owners can alienate their individual shares under Article 493 of the Civil Code. Despite the respondent corporation not signing the contract, its partial performance by paying option money demonstrated consent. The decision established that clear contractual terms control interpretation and that co-owners' individual property rights allow independent disposition of their shares without requiring consent from all co-heirs.