Petitioner
Heirs of Leopoldo Esteban, Sr.
Respondent
Lynda Lim Llaguno
Citation
G.R. No. 255001
Court
Supreme Court
Division
Third Division
Ponente
Caguioa, J.
Decided
June 14, 2023

Summary

This landmark case addressed whether co-owners can evict a lessee who contracted with only one co-owner without others' consent. The Supreme Court established that while an unauthorized lease of co-owned property by one co-owner without consent is invalid against non-consenting co-owners, it remains valid as to the leasing co-owner's ideal share under Civil Code Article 493. The Court applied co-ownership principles, ruling that since co-owners cannot eject each other from commonly-owned property, they similarly cannot eject someone possessing on behalf of a co-owner. The decision requires partition as a prerequisite to exclusive possession rights, protecting both co-ownership integrity and preventing unjust dispossession. While petitioners cannot evict the lessee, they remain entitled to their proportionate share of rentals from the unauthorized lease period, balancing co-owners' competing interests and establishing important precedent for similar co-ownership disputes.

Statutes applied

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By Intellegal Editorial Board · June 14, 2023

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