Coronel v. Constantino
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns ownership of two parcels of land in Sta. Monica, Hagonoy, Bulacan, originally owned by Honoria Aguinaldo. One half was inherited by Emilia Meking Vda. de Coronel and her sons (Benjamin, Catalino, and Ceferino), and the other half by Florentino Constantino and Aurea Buensuceso. Constantino and Buensuceso filed a complaint for declaration of ownership, quieting of title, and damages, alleging that Emilia, through a deed of sale on April 23, 1981, sold her share to Jess C. Santos and Priscilla Bernardo, who subsequently sold it to them. They claimed the Coronel defendants were illegally constructing on the premises and sought confirmation of their ownership over a one-third portion. 2. Procedural History: Florentino Constantino and Aurea Buensuceso filed a complaint against Benjamin Coronel, Emilia Meking Vda. de Coronel, and John Does with the Regional Trial Court of Bulacan. The trial court ruled in favor of the plaintiffs, declaring them the sole and absolute owners of the property and ordering the defendants to respect their ownership, remove improvements, and pay attorney's fees. The defendants appealed to the Court of Appeals, which affirmed the trial court's decision and denied their motion for reconsideration. 3. The Petition: The petitioners, Benjamin Coronel and Emilia Meking Vda. de Coronel, seek review on certiorari of the Court of Appeals' decision. They raise issues concerning the enforceability of a sale executed by a parent-co-owner regarding the shares of her children, the ratification of unauthorized actions by minor children, whether co-heirs are indispensable defendants, and the sufficiency of proof for a private deed of sale. The petitioners argue that the sale was only valid for Emilia's share, as Benjamin did not sign the deed, and the shares of Catalino and Ceferino were not included. They also contend that their inaction did not constitute ratification of the sale and that they did not benefit from it.
Issue(s)
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. Whether or not minor children can ratify unauthorized actions of their parents. Whether or not co-heirs are indispensable defendants in an action for declaration of ownership and quieting of title. Whether or not the deed of sale, a private document, was sufficiently established when the counsel for the defendants-petitioners admitted only its existence but not its contents.
Ruling
The Supreme Court modified the decision of the Court of Appeals. It declared Florentino Constantino and Aurea Buensuceso as owners of one-half (1/2) undivided portion of the subject property plus the one-fourth (1/4) undivided share of Emilia Meking Vda. de Coronel. Benjamin Coronel, together with the heirs of Catalino Coronel and the heirs of Ceferino Coronel, were declared owners of one-fourth (1/4) share each of the other one-half (1/2) portion. The order for removal of improvements and the award of attorney's fees were deleted.
Ratio Decidendi
On the enforceability of the sale by a co-owner: The Court held that the Deed of Sale executed by Emilia Meking Vda. de Coronel was valid only with respect to her own share in the co-owned property, as per Article 493 of the Civil Code. Benjamin Coronel did not sign the deed, making it unenforceable against his share. Similarly, the shares of Catalino and Ceferino were not subject to the sale. Therefore, the sale was limited to Emilia's pro-indiviso share. On ratification by minor children: The Court disagreed with the Court of Appeals' finding that the sons of Emilia ratified the sale through inaction and silence. The Court emphasized that ratification requires a voluntary act of adopting an unauthorized act, which presupposes knowledge of the transaction. Since no evidence was presented to show that Catalino, Ceferino, and Benjamin were aware of the sale made by their mother, their silence and inaction could not be interpreted as ratification. Furthermore, there was no concrete evidence that they benefited from the sale. On indispensable parties: The Court ruled that the heirs of Catalino and Ceferino were not indispensable parties. Indispensable parties are those without whom no final determination of the action can be had. In this case, a complete determination of the rights of the petitioners and respondents could be made even without impleading the heirs of Catalino and Ceferino. Moreover, the petitioners were estopped from raising this issue for the first time on appeal, as they actively participated in the trial proceedings without raising the matter of jurisdiction. On the sufficiency of evidence for the deed of sale: The Court found that the due execution of the "Kasulatan ng Bilihang Patuluyan" was established when the petitioners' counsel admitted during the pre-trial conference that the document was signed by Emilia. While the petitioners alleged that Emilia mistakenly believed it was a mortgage, no competent evidence was presented to support this claim. Thus, the sale of Emilia's share to Santos and Bernardo was validly established.
Main Doctrine
A contract entered into in the name of another by one who has no authority or legal representation, or who has acted beyond his powers, is unenforceable unless ratified, expressly or impliedly, by the person on whose behalf it has been executed. Silence and inaction, without knowledge of the transaction, do not constitute ratification.