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BENJAMIN CORONEL v. FLORENTINO CONSTANTINO

FACTS:

The case revolves around a dispute concerning two pieces of land located in Sta. Monica, Hagonoy, Bulacan. Originally owned by Honoria Aguinaldo, the property was later inherited by various individuals. Specifically, one-half of the land was inherited by Emilia Meking Vda. de Coronel and her sons, while the other half was inherited by Florentino Constantino and Aurea Buensuceso.

Constantino and Buensuceso initiated legal proceedings against Emilia and her sons, seeking a declaration of ownership and quieting of title. They claimed that they had purchased the property from the defendants and accused them of engaging in construction activities on the premises without their consent.

Following a trial, the trial court sided with the plaintiffs, ruling in their favor. The court declared the plaintiffs as the sole owners of the properties and ordered the defendants to remove the improvements made and pay attorney's fees and costs of suit. This decision was subsequently affirmed by the Court of Appeals.

Unsatisfied with the outcome, the defendants filed a petition for review on certiorari. They raised numerous issues in their petition, including the enforceability of a sale executed by a co-owner, the ratification of unauthorized actions by minor children, and whether all co-heirs were properly included as defendants in the case.

ISSUES:

  1. Whether or not the contract of sale executed by a parent-co-owner, in her own behalf, is unenforceable with respect to the shares of her co-heirs-children.

  2. Whether or not the co-heirs are indispensable defendants in an action for declaration of ownership and quieting of title.

  3. Whether or not the deed of sale, which is a private document, was sufficiently established when the counsel for the defendants-petitioners admitted only its existence but not its contents.

RULING:

  1. The Supreme Court ruled that the contract of sale executed by a parent-co-owner, in her own behalf, is unenforceable with respect to the shares of her co-heirs-children. The Court based its ruling on the fact that the contract of sale only pertained to the share of Emilia in the subject property and did not include the shares of her co-heirs.

  2. The Court ruled that the co-heirs were not indispensable defendants in the action for declaration of ownership and quieting of title. The Court stated that the complaint did not need to implead the heirs of Ceferino and Catalino, who died before the filing of the complaint, as indispensable parties.

  3. The Court held that the deed of sale, being a private document, was sufficiently established when the counsel for the defendants-petitioners admitted its existence. The admission of the existence of the document was enough to prove its existence and validity.

PRINCIPLES:

  • A contract of sale executed by a parent-co-owner, in her own behalf, is unenforceable with respect to the shares of her co-heirs-children if the contract only pertains to her share and does not include the shares of her co-heirs.

  • The issue of whether or not minor children can ratify unauthorized actions of their parents was not fully discussed in the case.

  • In an action for declaration of ownership and quieting of title, the heirs of co-owners who died before the filing of the complaint may not be considered indispensable parties.

  • The existence of a private document may be sufficiently established through the admission of its existence by the opposing party.