Ronquillo v. Liwanag

Summary

This case involved a dispute over property co-ownership rights where Ramon Mercado sold a specific divided portion of co-owned property to Pio D. Liwanag without his co-owner sister-in-law Basilia Mercado's consent. The plaintiffs sought to annul the deed of sale arguing that Article 493 of the Civil Code only permits disposal of undivided aliquot shares, not specific divided portions by metes and bounds. The Supreme Court affirmed the trial court's dismissal, ruling that while the deed improperly described a divided portion, the resulting Transfer Certificate of Title correctly reflected the buyer as co-owner of an undivided half-share. Since the end-result complied with Article 493's requirements and the vendor had the absolute right to dispose of his undivided share, the sale was valid. The Court emphasized that the title serves as the conclusive repository of co-owners' rights.