sc.judiciary.gov.ph/jurisprudence/2012/october2012/175990.pdf
"x x x.
Article 487 of the Civil Code provides that anyone of the co-owners may bring an action for ejectment without joining the others. The action is
not limited to ejectment cases but includes all kinds of suits for recovery of
possession because the suit is presumed to have been instituted for the
benefit of all.
In the case of Celino v. Heirs of Alejo and Teresa Santiago, the Court held that:
Respondents herein are co-owners of two parcels of land owned by their deceased mother. The properties were allegedly encroached upon by the petitioner. As co-owner of the properties, each of the heirs may properly bring an action for ejectment, forcible entry, or any kind of action for the recovery of possession of the subject properties. Thus, a co-owner may bring such an action, even without joining all the other co-owners as co-plaintiffs, because the suit is deemed to be instituted for the benefit of all.
However, if the action is for the benefit of the plaintiff alone, such
that he claims the possession for himself and not for the coownership, the action will not prosper.
Also, in the case of Carandang v. Heirs of De Guzman this Court ruled that a co-owner was not even a necessary party to an action for ejectment, for complete relief could be afforded even in his absence, thus:
In sum, in suits to recover properties, all co-owners are real parties in interest. However, pursuant to Article 487 of the Civil Code and the relevant jurisprudence, any one of them may bring an action, any kind of action for the recovery of co-owned properties. Therefore, only one of the co-owners, namely the co-owner who filed the suit for the recovery of the co-owned property, is an indispensable party thereto. The other co-owners are not indispensable parties. They are not even necessary parties, for a
complete relief can be afforded in the suit even without their participation, since the suit is presumed to have been filed for the benefit of all co-owners.
In the case at bench, the complaint clearly stated that the disputed
property was held in common by the petitioners; and that the action was
brought to recover possession of the lots from respondents for the benefit of all the heirs of Albina. Hence, Exequiel, a co-owner, may bring the action for unlawful detainer even without the special power of attorney of his coheirs, for a complete relief can be accorded in the suit even without their participation because the suit is deemed to be instituted for the benefit of all the co-owners.
x x x."
