Reynaldo Reyes v. Sps. Wilfredo

Summary

This case involves a property dispute over inherited co-owned land. Julian Reyes owned 463 sqm in Taguig which became co-owned by his nine heirs after his death. The heirs sold half to co-heir Anastacio in 1975, leaving 231.5 sqm co-owned. In 1989, heir Isidoro sold a portion to spouses Garcia, prompting petitioner (another heir) to seek nullification of the sale. The Supreme Court affirmed lower courts' rulings that a co-owner may validly sell his pro indiviso share under Article 493 of the Civil Code, but such sale affects only the seller's undivided interest, not other co-owners' shares. The Court emphasized that the proper remedy is partition under Article 494, not nullification of sale. This decision clarifies co-ownership rights and establishes that purchasers from co-owners acquire only the seller's proportionate abstract share until actual partition occurs.