GR 160346; (August, 2009) (Digest)
G.R. No. 160346 ; August 25, 2009
PURITA PAHUD, SOLEDAD PAHUD, and IAN LEE CASTILLA (represented by Mother and Attorney-in-Fact VIRGINIA CASTILLA), Petitioners, vs. COURT OF APPEALS, SPOUSES ISAGANI BELARMINO and LETICIA OCAMPO, EUFEMIA SAN AGUSTIN-MAGSINO, ZENAIDA SAN AGUSTIN-McCRAE, MILAGROS SAN AGUSTIN-FORTMAN, MINERVA SAN AGUSTIN-ATKINSON, FERDINAND SAN AGUSTIN, RAUL SAN AGUSTIN, ISABELITA SAN AGUSTIN-LUSTENBERGER and VIRGILIO SAN AGUSTIN, Respondents.
FACTS
The case involves a parcel of land inherited by the eight San Agustin siblings from their deceased parents. In 1992, Eufemia San Agustin, along with her brothers Ferdinand and Raul, executed a Deed of Absolute Sale conveying their undivided shares to petitioners Purita Pahud, et al. Eufemia also signed the deed on behalf of four other siblings: Isabelita (with a special power of attorney) and Zenaida, Milagros, and Minerva (without written authority). The Pahuds paid a substantial portion of the purchase price and secured the release of the property’s mortgage. However, a co-heir, Virgilio San Agustin, later refused to cooperate in transferring title. Subsequently, in a separate judicial partition proceeding, seven siblings, including Eufemia, entered into a Compromise Agreement to sell their shares to Virgilio, who then sold the entire property to respondents Spouses Isagani Belarmino and Leticia Ocampo.
ISSUE
The core issue is whether the sale of the undivided shares by Eufemia San Agustin on behalf of her co-heirs Zenaida, Milagros, and Minerva—without their written authority—is valid and binding upon them.
RULING
The Supreme Court reversed the Court of Appeals and upheld the validity of the sale to the Pahuds. The legal logic rests on the principle of ratification under Article 1900 of the Civil Code. While the sale initially suffered from Eufemia’s lack of written authority for three siblings, their subsequent conduct constituted implied ratification, curing the defect. The Court found that Zenaida, Milagros, and Minerva, through their silence and acceptance of benefits from the sale (including the Pahuds’ payments used to settle the estate’s mortgage and their participation in the judicial partition proceedings where the prior sale was acknowledged), confirmed and adopted Eufemia’s unauthorized acts. Ratification can be express or implied from acts showing an intention to adopt the transaction. Consequently, the sale to the Pahuds was deemed valid as to 7/8 of the property. The subsequent sale by Virgilio to the Belarminos, who were found to be buyers in bad faith with knowledge of the prior transaction, was declared invalid. The Court reinstated the trial court’s decision with modification, ordering the Pahuds to pay the balance of the purchase price.