Reman Recio v. Heirs of the Spouses Aguedo

Summary

This case involves a dispute over the validity of an oral contract of sale of real property between Reman Recio and the Altamirano heirs. Petitioner made partial payments totaling P160,000 to Alejandro Altamirano, who claimed to represent his co-heirs in selling their inherited property. When Alejandro avoided completing the sale, the property was sold to another buyer. The Supreme Court affirmed the Court of Appeals' modified decision, emphasizing that Articles 1874 and 1878 of the Civil Code require written special power of attorney for agents selling immovable property. Since Alejandro lacked written authority from his co-heirs, the sale was valid only as to his individual aliquot share. The decision establishes important precedent on agency requirements in real property sales and co-owners' rights to dispose of their undivided interests. The case demonstrates the strict compliance required for agency in real property transactions and the legal consequences when proper authorization is lacking.