Reman Recio v. Heirs of the Spouses Aguedo and Maria Altamirano and Spouses Lauro and Marcelina Lajarca
### Facts:
In the 1950s, Nena Recio leased a parcel of land in Lipa City from the Altamiranos. In 1988, the Altamiranos offered to sell the property to Nena for P500,000.00, waivering rentals. The sale did not materialize due to the Altamiranos’ fault, but Nena continued occupancy with their consent. The property was eventually consolidated, subdivided, and covered by TCT No. T-102563, with the Recios maintaining possession.
In 1994, Nena’s option to buy was renewed through negotiations between Reman Recio (Nena’s son) and Alejandro Altamirano, resulting in an oral contract of sale in 1995 with partial payments made by Recio. Despite efforts, Recio could not complete the payment due to Alejandro’s avoidance, leading Recio to demand a Deed of Absolute Sale, which prompted a lawsuit for Specific Performance with Damages against the Altamiranos in 1997.
During the proceedings, it was discovered that the Altamiranos sold the property to the Spouses Lajarca in 1998, after which the complaint was amended to include the annulment of this sale. Alejandro testified briefly but failed to return, leading to a ruling favoring Recio, including annulment of the Lajarca sale and ordering the Altamiranos to execute a Deed of Absolute Sale to Recio.
The Lajarcas appealed the RTC decision, leading to a CA ruling that affirmed the decision with modifications, primarily altering the effective ownership to reflect only Alejandro’s share being sold to Recio due to lack of written authority from other Altamiranos.
### Issues:
1. Validity of the verbal contract of sale between Alejandro and Reman Recio, given the lack of written authority from other Altamirano heirs.
2. The legal effect of the Deed of Absolute Sale between the Altamiranos and the Spouses Lajarca considering the prior, yet incomplete, sale to Recio.
3. The application of the principles governing co-ownership, agency, and the rights of buyers in good faith.
### Court’s Decision:
The Court upheld the CA’s findings. It ruled that Alejandro only had the authority to sell his share of the property, making the sale valid only as to his aliquot share due to missing written authority from the other co-owners. It also affirmed that the Petitioner, Reman Recio, could not fully acquire the property based solely on the oral contract with Alejandro without a formal deed and complete payment. The subsequent sale to the Spouses Lajarca was held valid except for Alejandro’s share, now belonging to Recio, making them co-owners.
### Doctrine:
This case reiterates the requirement for written authority under Articles 1874 and 1878 of the Civil Code in selling real property by an agent and the principle that a co-owner is entitled to sell his undivided interest without consent from the other co-owners.
### Class Notes:
1. **Agency in Real Property Sales**: Sale of real property by an agent requires written authority from the principal (Articles 1874 and 1878, Civil Code).
2. **Co-Ownership**: A co-owner may sell his undivided share independently of the other co-owners.
3. **Good Faith in Purchases**: Buyers must verify any existing claims or lis pendens on the property to be considered buyers in good faith.
4. **Specific Performance**: A party can be compelled to complete a contractually agreed-upon sale if the conditions for the sale are met.
### Historical Background:
The scenario underscores common issues in Philippine land transactions, including the complexity of property co-ownership, requirements for authority in sales, and disputes arising from verbal contracts in property deals. It reflects the legal requirements for formalizing real estate transactions to prevent conflicts and ensure clarity in property rights and ownership.
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