JUSTICE BUSBY delivered the opinion of the Court. This appeal concerns the amount of royalty petitioner ConocoPhillips Company owes respondent Kenneth Hahn, who owns a non-participating royalty interest (NPRI) in production from a mineral estate leased by ConocoPhillips. ConocoPhillips’s petition asks whether Hahn’s right to a 1/8 fixed share of production was reduced when Hahn either (1) ratified a subsequent lease by the owner of the mineral estate that includes its own royalty term, or (2) signed a later stipulation and cross-conveyance agreeing to accept a different royalty. The court of appeals held that neither the ratification nor the stipulation and cross- conveyance reduced Hahn’s NPRI. We agree with the court of appeals regarding ratification but disagree regarding the stipulation. We hold that Hahn’s NPRI was not altered by the royalty term of the ratified lease, in which the fee owners of the mineral estate granted ConocoPhillips their rights to possess and extract minerals in exchange for a royalty. As we explained in Hysaw v. Dawkins, a non-possessory royalty interest “conveys a fixed share of production” rather than “a fraction of the total royalty interest” and thus “remains constant regardless of the amount of royalty contained in a subsequently negotiated oil and gas lease.” 483 S.W.3d 1, 9 (Tex. 2016). We also hold, however, that Hahn later reduced his NPRI by conveying part of it to the mineral fee owner in the stipulation and cross- conveyance. The court of appeals’ failure to give effect to the stipulation and cross-conveyance was contrary to our recent decision in Concho Resources, Inc. v. Ellison, 627 S.W.3d 226 (Tex. 2021). We therefore reverse the court of appeals’ judgment in part and render judgment that ConocoPhillips correctly calculated Hahn’s share of proceeds from the production on the pooled unit. Background The creation of Tract A and Tract B Following the death of their father, Kenneth Hahn and his three siblings owned varying interests in a 74.15 acre tract of land. Hahn and his brother, George, owned the tract’s surface estate as cotenants while each of the four Hahn siblings owned a 1/4 undivided share of the tract’s severed mineral estate. In August 2002, the two brothers executed and recorded two deeds (the 2002 Partition Deeds) through which Hahn received exclusive surface ownership of the northeast 37.07 acres (Tract A) and his brother, George, received surface ownership of the southwest 37.07 acres (Tract B). The Gips Deed and Gips Lease Later that year, Hahn executed and recorded a general warranty deed conveying Tract A to William and Lucille Gips. The Gips Deed includes the following reservation: SAVE AND EXCEPT [that] there is hereby reserved unto [Kenneth Hahn], his heirs and assigns, an undivided one- half (1/2) non-participating interest in and to all of the royalty [Kenneth] now owns, (same being an undivided one-half (1/2) of [Kenneth's] one-fourth (1/4) or an undivided one-eighth (1/8) royalty) in and to all of the oil royalty, gas royalty and royalty in other minerals in and under and that may be produced from the herein described property. This 1/8 NPRI was for a term of 15 years, concluding in June 2017. The deed also provides that Hahn and his heirs and assigns “shall not participate in the making of any oil, gas or mineral lease covering said property, nor shall they participate in any rental or shut-in gas well royalty to be paid under such lease.” In July 2010, the Gipses entered into an oil, gas, and mineral lease with ConocoPhillips for Tract A.[1] The Gips Lease provides that “[t]he royalties to be paid by Lessee” on oil and gas production are “1/4th of that produced and saved from said land.”[2] The lease also contains a pooling clause, which grants ConocoPhillips “the right and power to pool or combine the acreage covered by th[e] lease” and, upon pooling, requires the pro rata allocation of royalties on an acreage basis. The lease is for a primary term of three years and “as long thereafter as oil, gas or other mineral is produced from said land or land with which said land is pooled hereunder or as long as this lease is continued in effect as otherwise provided herein.” The Gips Lease imposes various limits on pooling, including that “[p]rior to exercising its right to pool or unitize any part of the lease premises, [ConocoPhillips] must obtain ratification of [the] lease by all holders of outstanding royalty, if any,” and that ConocoPhillips would “bear any excess royalty occasioned by [its] failure to obtain such ratification.” The lease also includes paragraphs that (1) expressly disclaim any warranty of title by the Gipses, (2) address the effect of any division orders, and (3) provide ConocoPhillips’s breach of any obligation will not be grounds for canceling the lease. The Lease Ratification and Stipulation In July 2011, Hahn and the Gipses executed a document titled “Ratification of Oil, Gas and Mineral Lease.” The Lease Ratification recites that Hahn owns an NPRI and includes the following language: NOW, THEREFORE, in consideration of the premises and other valuable consideration, the receipt of which is hereby acknowledged, I, Kenneth Hahn, do hereby ADOPT, RATIFY, and CONFIRM the Lease in all of its terms and provisions, and do hereby LEASE, GRANT, DEMISE and LET unto [ConocoPhillips], its successors and assigns, subject to and in accordance with all of the terms and provisions of the Lease as fully and completely as if I had originally been named as Lessor in the Lease and had executed, acknowledged and delivered the same. And I do hereby agree and declare that the Lease in all of its terms and provisions are binding on me and is a valid and subsisting oil, gas and mineral lease. According to Hahn, ConocoPhillips later approached him about the need to formally clarify certain aspects of the royalty interest he reserved in the Gips Deed. The resulting “Stipulation of Interest,” which Hahn and the Gipses signed on November 11, 2011, and recorded,[3] recites that the parties “wish to stipulate for the record the respective royalty interest owned by Kenneth Hahn in and to the Subject Lands.” The Stipulation also provides that for and in consideration of the premises, and other valuable considerations, the receipt and sufficiency of which are hereby acknowledged, each of the undersigned does hereby acknowledge, stipulate and agree that it was the intent of the parties in the deed from Kenneth Hahn to William Paul Gips and Lucille Fay Gips, recorded in Volume 121, Page 625, Official Public Records, DeWitt County, Texas, that the interest reserved was a one-eighth (1/8) “of royalty” for a term of 15 years from June 9, 2003. To effectuate the purposes of this Stipulation of Interest, each of the parties hereto does hereby grant, bargain, sell, convey, quitclaim and deliver unto each of the other respective parties any interest in the Subject Interest (as herein stipulated) necessary to vest in each of said respective parties the interest set opposite their name above, together with all rights incident thereto, to have and to hold the same to each of said parties and their respective successors, heirs and assigns forever. ConocoPhillips pools Tract A In March 2012, ConocoPhillips amended the designation of its production unit “Maurer Unit B” to include Tract A and other surrounding land,[4] retroactive to October 1, 2011. Hahn was provided with a division order dated May 3, 2012, which he asserts “correctly reflected” the fixed 1/8 NPRI he claims. Several months later, a representative for ConocoPhillips called Hahn to inform him of ConocoPhillips’s belief that Hahn no longer owned any interest in Tracts A or B, although Hahn claims he did not learn ConocoPhillips’s reasoning at that time. Initial proceedings in the trial court Hahn sued Conoco and the Gipses in March 2015, asserting a multitude of claims.[5] As relevant here, Hahn alleged a cause of action for trespass to try title to confirm his mineral ownership in Tracts A and B and sought declaratory relief. ConocoPhillips and the Gipses each filed answers generally denying Hahn’s allegations.[6] Hahn and the Gipses filed cross-motions for summary judgment to confirm their respective ownership interests in Tract A, among other relief. ConocoPhillips also moved to strike portions of two affidavits Hahn submitted as summary judgment evidence, arguing that they were inadmissible parol evidence. Following a hearing, the trial court denied Hahn’s motion for partial summary judgment, instead granting the Gipses’ motion and striking portions of the affidavits. The trial court declared that (1) the 2002 partition deeds conveyed each brother’s interest in Tracts A and B to the other brother, and (2) the Gips Deed conveyed all of Hahn’s then- existing ownership in Tract A to the Gipses, except for a floating “of royalty” equal to 1/8 of the landowner’s royalty set forth in any existing or future oil and gas leases. Hahn’s first appeal (Conoco 1) In his initial appeal, Hahn obtained reversal of the summary judgment. Hahn v. Gips, No. 13-16-00336-CV, 2018 WL 771908 (Tex. App.—Corpus Christi–Edinburg Feb. 8, 2018, pet. denied) (Conoco 1). Hahn argued the trial court erred in construing the deeds executed in 2002 and by giving effect to the Stipulation, which Hahn argued failed as a conveyance, correction deed, or contract and did not estop him from relying on the four corners of the Gips Deed. Hahn also argued the trial court’s exclusion of the affidavits constituted harmful error. Agreeing with Hahn, the court of appeals reversed and rendered judgment in part, holding that (1) following his execution of the 2002 partition deeds, Hahn owned a one-fourth undivided interest in the mineral estate of Tracts A and B, and (2) the Gips Deed unambiguously reserved to Hahn a fixed 1/8 NPRI in Tract A. Id. at *9. The court of appeals further held that the Stipulation could not be considered because it was outside the four corners of the unambiguous Gips Deed, and therefore the Gipses were estopped from claiming more than a 1/4 mineral interest under the Gips Deed. Id. at *8 & n.5. The court did not reach Hahn’s remaining issues, including his challenge to the trial court’s evidentiary ruling, and remanded to the trial court for further proceedings. Id. at *9. This Court denied review. Post-remand proceedings in the trial court The parties returned to the trial court and Hahn filed an amended petition. In addition to his previously asserted causes of action, Hahn added a claim for statutory underpayment of royalties under Chapter 91 of the Texas Natural Resources Code, contending he was entitled to additional proceeds from the sale of oil and gas attributed to Tract A and Tract B. ConocoPhillips and the Gipses each filed amended answers generally denying Hahn’s allegations and asserting several affirmative defenses, including ratification. ConocoPhillips also asserted a counterclaim for relief under the Uniform Declaratory Judgments Act (UDJA), TEX. CIV. PRAC. & REM. CODE § 37.001 et seq. Relying on Hahn’s execution of the Lease Ratification, ConocoPhillips sought a declaration that Hahn’s ratification of the Gips Lease made his share of the proceeds from production subject to the royalty stated in the lease, as well as an award of costs and reasonable attorney’s fees under the UDJA. Hahn filed his original answer to ConocoPhillips’s counterclaim on April 13, 2020, generally denying its allegations and pleading several affirmative defenses. In addition to challenging whether the counterclaim was proper under the UDJA, Hahn alleged the counterclaim was barred by laches, waiver, estoppel, and the law of the case. The parties filed new cross-motions for summary judgment on their competing royalty calculations for Tract A. They primarily disputed whether the royalty stated in the Gips Lease applied to Hahn’s share of proceeds from the pool and the extent to which the court of appeals’ decision in Conoco 1 foreclosed certain arguments. ConocoPhillips contended that Hahn’s execution of the Lease Ratification and his receipt of benefits under the Gips Lease—including the ability to receive a royalty on the entire pooled acreage of the Maurer Unit B (and not just from the unpooled Tract A)—bound him to the remaining lease terms, including its royalty provision. Conversely, Hahn argued he had conclusively established each element of his statutory underpayment claim for royalties from production on Tract A and sought summary judgment that ConocoPhillips is liable on that claim. Hahn’s motion also challenged the viability of ConocoPhillips’s counterclaim under the UDJA,[7] which he argued was untimely, contrary to the law of the case, and barred by the doctrines of estoppel, waiver, and laches. On the merits, Hahn argued the “fixed” nature of his NPRI means it is not capable of being diminished by the lease’s landowner royalty and that the Lease Ratification was effective only as to the lease’s pooling provision. The trial court again granted summary judgment in the defendants’ favor, declaring that ConocoPhillips’s royalty calculations were correct.[8] The court concluded that Hahn ratified the Gips Lease and is therefore bound by all terms within the lease, including its royalty provision. The court also concluded that ConocoPhillips was entitled to attorney’s fees under the UDJA. The parties entered into a stipulation regarding the amount of attorney’s fees, and the trial court signed a judgment in favor of ConocoPhillips. Hahn’s current appeal (Conoco 2) The court of appeals reversed the trial court a second time, holding that the Lease Ratification did not reduce Hahn’s NPRI from a fixed fractional interest in production to a floating fraction of the lease royalty then in effect. See 698 S.W.3d 274, 296-97 (Tex. App.—Corpus Christi–Edinburg 2022) (Conoco 2). Accordingly, the 1/4 landowner’s royalty stated in the Gips Lease was inapplicable to Hahn’s 1/8 NPRI in Tract A’s share of production from Maurer Unit B. The court also reaffirmed its prior holding in Conoco 1 that the 2011 Stipulation was incapable of diminishing Hahn’s interest as reserved in the Gips Deed,[9] distinguishing our intervening decision in Concho Resources, Inc. v. Ellison, 627 S.W.3d 226 (Tex. 2021). See Conoco 2, 698 S.W.3d at 285-87. The court of appeals rendered judgment in part that Hahn’s calculation of the applicable royalty decimal was correct and remanded for the trial court to consider Hahn’s request for attorney’s fees. Id. at 295-97. The court also agreed with Hahn that ConocoPhillips’s UDJA claim was improper because it duplicated defensive matters already before the court. Id. at 296.[10] This appeal followed. Analysis As our starting point, we assume without deciding that the court of appeals correctly held in Conoco 1 that the Gips Deed reserved a fixed 1/8 NPRI for Hahn.[11] Raising a defense of ratification, ConocoPhillips contends this fixed NPRI was later converted into 1/8 of the 1/4 royalty in the Gips Lease—that is, a floating NPRI—for two separate and independent reasons: (1) Hahn ratified the Gips Lease; and (2) Hahn signed the Stipulation. Hahn defends the court of appeals’ holdings that the Lease Ratification did not reduce his NPRI and that our decision in Concho Resources does not permit ConocoPhillips to rely on the Stipulation. Hahn also urges us to affirm the court of appeals’ judgment because the Stipulation is ineffective on alternative grounds. We first agree with the court of appeals that the Lease Ratification did not subject Hahn’s NPRI to the Gips Lease’s royalty provision. As explained below, the ratification does not subject the NPRI to lease provisions that are otherwise inapplicable to non-possessory interests in production. We therefore reject ConocoPhillips’s contention that the Lease Ratification supports reinstatement of the trial court’s judgment. Turning to the Stipulation, however, we disagree with the court of appeals’ conclusion that our holding in Concho Resources “does not bear on” its prior interpretation of the 2011 Stipulation in Conoco 1 or other documents outside the four corners of a deed. 698 S.W.3d at 287. Finally, we reject Hahn’s arguments that the Stipulation is ineffective as a conveyance. The Lease Ratification did not change Hahn’s NPRI from fixed to floating. The first issue is what happened when Hahn—who owned a 1/8 fixed non-participating royalty interest (NPRI) in production from Tract A—ratified the entirety of the Gips Lease, which pays the Gipses a 1/4 royalty on production in exchange for the lease of their mineral estate in Tract A. The trial court’s final judgment in Conoco 2 declared: (1) “Hahn has ratified the Gips Lease and is therefore bound by all terms in that Gips Lease”; and (2) “based on that ratification, and as it applies solely to Kenneth Hahn’s ownership interest in Tract A,” ConocoPhillips correctly identified the applicable unit decimal interest for calculating Hahn’s share of production from Maurer Unit B. Reversing, the court of appeals held that Hahn, in ratifying the Gips Lease, “agreed to have his fixed one-eighth NPRI [in production] subject to Tract A’s tract participation rate in [the pooled] Maurer Unit B” but not to have that interest diminished by the landowner’s royalty fraction under the lease. Id. at 290, 292. “As an NPRI owner, [Hahn] has no executive rights and is, therefore, due none of the entitlements owed to the lessor under the lease”—including “a landowner’s royalty.” Id. at 294. Thus, it is “obviously unsound” to apply the terms of those entitlements to Hahn’s interest in production. Id. We agree. Texas has adopted the view “that pooling effects a cross- conveyance among the owners of minerals under the various tracts of royalty or minerals in a pool so that they all own undivided interests under the unitized tract in the proportion their contribution bears to the unitized tract.” Montgomery v. Rittersbacher, 424 S.W.2d 210, 213 (Tex. 1968). “Though governed by contract, pooling involves property rights,” Samson Explor., LLC v. T.S. Reed Props., Inc., 521 S.W.3d 766, 775 (Tex. 2017), and “pooling on the part of the holder of the executive rights cannot be binding upon the non-participating royalty owner in the absence of his consent,” Montgomery, 424 S.W.2d at 213.[12] Instead, an NPRI owner like Hahn “has the option to ratify or repudiate a lease containing provisions which as to his interest the holder of the executive rights had no authority to insert in the lease.” Id. at 215. But if an NPRI owner “ratifies” a separate “pooling agreement” or a lease containing such an agreement, “either by joining in the execution of the agreement or by accepting royalties from the pool, his interest is bound by the pooling agreement.” Id.; see also Verble v. Coffman, 680 S.W.2d 69, 70 (Tex. App.—Austin 1984, no writ) (“Ratification of an oil and gas lease by non-participating royalty interest owners . . . has been construed as an offer made by the lessor, and accepted by the royalty owners to apportion all proceeds from the lease.”). “A party ratifies an agreement when—after learning all of the material facts—he confirms or adopts an earlier act that did not then legally bind him and that he could have repudiated.” White v. Harrison, 390 S.W.3d 666, 672 (Tex. App.—Dallas 2012, no pet.).[13] “Express ratification—in writing, for example—typically makes the parties’ intentions clear.” BPX Operating Co. v. Strickhausen, 629 S.W.3d 189, 197 (Tex. 2021). Additionally, “[r]atification may occur when a principal, though he had no knowledge originally of the unauthorized act of his agent, retains the benefits of the transaction after acquiring full knowledge.” Land Title Co. of Dallas, Inc. v. F.M. Stigler, Inc., 609 S.W.2d 754, 756 (Tex. 1980).[14] “[R]atification is a plea in avoidance and thus is an affirmative defense which must be pleaded.” Petroleum Anchor Equip., Inc. v. Tyra, 419 S.W.2d 829, 834 (Tex. 1967). “When the facts are uncontroverted . . . the court may decide the question of ratification as a matter of law.” BPX Operating Co., 629 S.W.3d at 196. Each party’s briefing devotes significant space to arguing about whether the other party is giving appropriate effect to the Lease Ratification. But the proper rule is straightforward: a ratifier is bound to the “entire transaction” and “may not, in equity, ratify those parts of the transaction which are beneficial and disavow those which are detrimental.” Land Title Co., 609 S.W.2d at 757.[15] Thus, an NPRI holder’s ratification of an oil and gas lease means any lease provision that can apply to an NPRI is binding on the holder. As ConocoPhillips correctly recognizes, applying this rule requires “filtering [Hahn's] royalty interest through a lease agreement that covers a plurality of interests (surface, mineral, and royalty)—some provisions of which can conceivably apply to some of those interests (including Hahn’s), and others that cannot.” Our conclusion that the Gips Lease’s royalty provision does not apply to Hahn’s non-possessory interest in production flows from the different nature of the property interests involved.[16] An NPRI is a fractional non-possessory interest in oil and gas produced from the tract.[17] It is not ownership of the mineral fee itself, which comes with the rights to possess oil and gas in the ground, to extract it, and to lease those property rights to others. Hysaw, 483 S.W.3d at 9. Nor is it a fractional title to that mineral fee—a so-called non-executive mineral interest (NEMI).[18] This understanding of Hahn’s interest informs which provisions of the Gips Lease can apply to that interest. Some provisions in a standard mineral lease certainly apply to an NPRI: for example, as discussed above, we have long held that an NPRI can be pooled.[19] And the parties seem to agree that other provisions do not apply to an NPRI: for example, that Hahn would not be entitled to share in delay rentals or shut-in royalties, which involve no production.[20] Does a standard lease provision obligating the lessee to pay royalties to the mineral fee owner also apply to a pre-existing fixed NPRI, making it a floating NPRI? Under our cases, the answer is no. As we explained in Hysaw v. Dawkins, [r]oyalty interests may be conveyed or reserved as a fixed fraction of total production (fractional royalty interest) or as a fraction of the total royalty interest (fraction of royalty interest). A fractional royalty interest conveys a fixed share of production and remains constant regardless of the amount of royalty contained in a subsequently negotiated oil and gas lease. In comparison, a fraction of royalty interest (as a percentage of production) varies [or "floats"] in accordance with the size of the landowner’s royalty in a mineral lease and is calculated by multiplying the fraction in the royalty reservation by the royalty provided in the lease. 483 S.W.3d at 9 (internal quotation marks and citations omitted, emphasis added). Because Hahn’s interest is a fixed share of production, it remains constant regardless of the amount of royalty stated in the subsequently negotiated Gips Lease.[21] Our conclusion comports with the general rule that an NPRI holder’s interest in oil and gas produced from the tract is not leasable. See Nat. Gas Pipeline Co. of Am. v. Pool, 124 S.W.3d 188, 192 (Tex. 2003) (“A royalty interest, as distinguished from a mineral interest, is a non- possessory interest.”); Hawkins v. Tex. Oil & Gas Corp., 724 S.W.2d 878, 888 (Tex. App.—Waco 1987, writ ref’d n.r.e.) (explaining that lease executed by royalty owner is void because “the doctrine of estoppel cannot create rights where none exist”); see also 1 H. Williams & C. Meyers, OIL & GAS LAW § 303.3 (2023 ed.) (“A royalty owner has no power to lease, and a purported lease from him is void.” (footnotes omitted)). Indeed, the Gips Deed itself expressly prohibits Hahn from “participat[ing] in the making of any oil, gas or mineral lease covering said property.” Instead, ConocoPhillips agreed to pay the mineral fee owners a 1/4 royalty in exchange for fee simple determinable ownership of the minerals themselves. That ownership includes the rights to possess the oil and gas in place under the tract and to extract it—rights that were held entirely by the Gipses. See Lightning Oil Co. v. Anadarko E&P Onshore, LLC, 520 S.W.3d 39, 49 (Tex. 2017); Coastal Oil & Gas Corp. v. Garza Energy Tr., 268 S.W.3d 1, 15 (Tex. 2008). Thus, the lessor royalty provision in the Gips Lease does not apply to Hahn’s NPRI.[22] Of course, as the court of appeals noted, a non-possessory royalty interest in production can easily be affirmatively modified or transferred in whole or in part in other ways, including by assignment. See 698 S.W.3d at 292 (citing Montgomery, 424 S.W.2d at 214). But the Gips Lease that Hahn ratified does not purport to do so. To the contrary, certain language in the Gips Lease supports the conclusion that the lease royalty does not apply to an NPRI. For example, the pooling clause provides that when “computing the royalties to which owners of royalties and payments out of production and each of them shall be entitled on production of oil and gas . . . from the pooled unit,” ConocoPhillips’s pro rata allocation “shall be on an acreage basis.” The lease’s pooling clause thus distinguishes between (1) royalties and (2) payments out of production, which suggests that the lease’s provision fixing the amount of the mineral interest owner’s royalty does not apply to the payments out of production owed to an NPRI. We cannot agree with ConocoPhillips that an NPRI holder’s ratification of the entire lease negates the operative effect of language within the pooling clause distinguishing between the two types of payments. For these reasons, the royalty provision of the Gips Lease does not reduce Hahn’s NPRI. The Stipulation changed Hahn’s NPRI from fixed to floating. ConocoPhillips’s second challenge to the court of appeals’ judgment in Conoco 2 concerns the Stipulation that the NPRI reserved to Hahn in the Gips Deed “was a one-eighth (1/8) ‘of royalty.’” All parties agree that if this Stipulation was effective, Hahn’s NPRI in Tract A is floating rather than fixed—that is, the 1/4 royalty fraction in the Gips Lease reduces the 1/8 NPRI fraction. Their dispute concerns whether the Stipulation was effective. The court of appeals held in Conoco 1 that because the Gips Deed unambiguously reserved a fixed NPRI for Hahn, the Stipulation was immaterial to the deed’s meaning and the trial court violated the four corners rule by considering it. 2018 WL 771908, at *8 n.4. Then, in Conoco 2, the court of appeals concluded our intervening decision in Concho Resources did not warrant reconsidering this holding because that case (1) concerned a boundary that (2) was uncertain or ambiguous in the minds of the parties. 698 S.W.3d at 287. The parties disagree about whether Concho Resources is distinguishable for these reasons, as well as whether the Stipulation is ineffective on alternative grounds urged by Hahn. We address these issues in turn. A written agreement to settle matters of property ownership can be enforced without proof of uncertainty. In Concho Resources, we considered a written boundary stipulation that recited “[o]n its face” the parties’ desire to answer a “question that has arisen among the owners of the adjacent mineral estates” regarding the physical location of the two tracts and the boundary line between them. 627 S.W.3d at 234 (cleaned up). The stipulation described the boundary line to which the parties agreed in return for adequate consideration and provided for conveyances as necessary to transfer ownership accordingly. Rejecting the lower court’s holding that such agreements are void unless there is some ambiguity or error in the underlying instrument(s) of conveyance, we held that the boundary stipulation “is enforceable between the parties according to its terms.” Id. Although “the boundary stipulation could not by itself bind others who had an interest in the tracts and were not parties to the agreement,” it constituted “a valid agreement between the mineral owners of the two tracts at issue.” Id. at 236. Similarly here, the written stipulation recites Hahn’s and the Gipses’ “wish to stipulate” as to their interests “for purposes of clarifying their ownership.” It then provides that for adequate consideration, the parties agree Hahn’s reserved interest was a 1/8 “of royalty,” and it includes cross-conveyance language to effectuate the stipulation. Yet the court of appeals concluded this stipulation was not enforceable under Concho Resources for two reasons. First, the court reasoned there was “no evidence in the 2011 stipulation of interest or elsewhere” of “ambiguity in the minds of the parties” as to Hahn’s correct royalty. 698 S.W.3d at 287. To the contrary, we observe that the Stipulation recites its purpose of “clarifying” the parties’ interests. But more importantly, we disagree with the court of appeals that proof of subjective uncertainty regarding the correct property interests is required before such a written stipulation can be given effect.[23] In Concho Resources, we declined to bind parties equitably to recitals in the underlying deeds, rejecting that estoppel theory as “a modified version of the argument that objective ambiguity is required to justify a boundary agreement.” 627 S.W.3d at 238. Adjacent owners’ “free[dom] to resolve uncertainty amongst themselves,” id., we said, is meaningless if a factfinder can “second-guess the owners’ decision to bind themselves in that manner,” id. at 235. “Settlement agreements are highly favored in the law because they are a means of amicably resolving doubts and preventing lawsuits.” Forest Oil Corp. v. McAllen, 268 S.W.3d 51, 60 n.33 (Tex. 2008). Requiring proof of ambiguity—whether objective or subjective—”would scuttle” agreements between property owners as to their respective interests “as a mechanism to avoid litigation because parties will never know whether their informal settlement of a boundary dispute is effective until it is declared so by a court.” Concho Res., 627 S.W.3d at 235 (internal quotation marks omitted). We declined to impose such a requirement in Concho Resources and decline again today. Second, the court of appeals read Concho Resources as limited to agreements establishing the physical location of a property boundary. 698 S.W.3d at 287 (declining to apply Concho Resources “outside the boundary dispute context”). Hahn urges that boundary agreements are governed by a special set of relaxed rules because they do not convey interests in real property[24] and remedy the historical unreliability of land surveys. But Concho Resources did not attribute any favored status to concerns particular to land boundaries. Instead, we emphasized deference to the owners’ “ch[oice] to resolve . . . the boundary location informally by executing [a] stipulation” despite their ability to obtain a court’s determination of the boundary. 627 S.W.3d at 235. We chose to recognize “agreements as a mechanism to avoid litigation” rather than making agreements the subject of potential litigation. Id. And we have specifically encouraged the use of stipulations about the nature or amount of an NPRI to avoid the need for judicial clarification.[25] Accordingly, neither of the court of appeals’ two distinctions of Concho Resources provides a reason for concluding that the Stipulation is unenforceable. We therefore turn to Hahn’s other arguments against enforcing the Stipulation. The court of appeals did not reach these alternative grounds, but we exercise our discretion to do so in the interest of judicial economy.[26] The Stipulation contains adequate descriptions from which the relevant property interests may be identified with reasonable certainty. Hahn raises two other arguments against enforcing the Stipulation that are not resolved by our discussion of Concho Resources. First, he contends the Stipulation is not enforceable as a conveyance because “[i]ts incoherent description of the interest to be conveyed renders its ‘operative’ language equally unintelligible.” Second, Hahn argues that the Stipulation is not enforceable as a contract for various reasons, including that his affidavit testimony rebutted the presumption of consideration arising from the instrument’s recitals. Because we conclude the Stipulation does not fail as a conveyance for the reason Hahn advocates, we need not address whether it is also enforceable as a contract. A valid conveyance of an interest in land “must satisfy the requirements of both the statute of conveyances, Property Code section 5.021, and the statute of frauds, Business and Commerce Code section 26.001.” Gordon v. W. Houston Trees, Ltd., 352 S.W.3d 32, 43 (Tex. App.—Houston [1st Dist.] 2011, no pet.). Otherwise, “it is not necessary to have all the formal parts of a deed formerly recognized at common law or to [include] technical words.” Harlan v. Vetter, 732 S.W.2d 390, 392 (Tex. App.—Eastland 1987, writ ref’d n.r.e.).[27] Thus, we have “eschew[ed] reliance on mechanical or bright-line rules as a substitute for an intent-focused inquiry rooted in the instrument’s words,” Hysaw, 483 S.W.3d at 13, and “rejected mechanical rules of construction, such as giving priority to certain clauses over others, or requiring the use of so-called ‘magic words,’” Wenske v. Ealy, 521 S.W.3d 791, 794 (Tex. 2017).[28] Although we endeavor to “giv[e] the deed’s words their plain meaning, reading it in its entirety, and harmonizing all of its parts,” id. at 797, “[w]hen part of a deed’s property description is incorrect, we will disregard that part as surplusage and enforce the deed if the remainder of the description identifies the land with sufficient certainty,” Piranha Partners v. Neuhoff, 596 S.W.3d 740, 745 n.12 (Tex. 2020).[29] “[It] is not the actual intent of the parties that governs, but the actual intent of the parties as expressed in the instrument as a whole, without reference to matters of mere form, relative position of descriptions, technicalities, or arbitrary rules.” Luckel, 819 S.W.2d at 462 (internal quotation marks omitted). Under these principles, the following elements are generally required for a deed to accomplish a legally effective conveyance:[30] (1) the instrument of conveyance is in writing;[31] (2) the interest to be conveyed is sufficiently described;[32] (3) the grantor and grantee can be ascertained from the instrument as a whole;[33] (4) there are operative words or words of grant showing an intention by the grantor to convey title to a real
