Case Digest (G.R. No. 143826)
Facts:
Heirs of Ignacia Aguilar-Reyes v. Spouses Cipriano Mijares and Florentina Mijares, G.R. No. 143826, August 28, 2003, Supreme Court First Division, Ynares‑Santiago, J., writing for the Court.The property at issue was Lot No. 4349‑B‑2 (TCT No. 205445), a 396.20 sq.m. parcel in Balintawak, Quezon City, held as conjugal property by Vicente Reyes and Ignacia Aguilar‑Reyes, purchased with conjugal funds from their garments business. The spouses had been married in 1960 but were de facto separated since 1974. Vicente executed an alleged sale of the lot to Spouses Cipriano and Florentina Mijares allegedly on March 1, 1983 (though earlier agreements indicate transactions as early as November 25, 1978). TCT No. 306087 was subsequently issued in the Mijareses' names.
Vicente filed special proceedings in the Metropolitan Trial Court of Quezon City, misrepresenting that Ignacia died on March 22, 1982; the court appointed him guardian of their minor children (Order, Sept. 29, 1983) and later authorized Vicente to sell Ignacia’s estate (Order, Oct. 14, 1983). Ignacia, learning of the sale in 1984, demanded reconveyance; on June 4, 1986 she filed a complaint for annulment of sale (later amended to include Vicente). Ignacia later died and her compulsory heirs (petitioners) were substituted.
The Regional Trial Court (Quezon City, Branch 101) initially, by decision dated February 15, 1990, declared the sale null and void only as to one‑half (Ignacia’s share) and ordered partial restitution and damages. On May 31, 1990 the trial court modified its judgment and declared the sale null and void ab initio for failure to obtain the wife’s conformity, ordered cancellation of the Mijareses’ title and reconveyance to the spouses Reyes, and directed Vicente to reimburse the full purchase price (P110,000) plus interest and to pay damages; a June 29, 1990 order corrected a TCT number and reiterated damages.
Both Ignacia (before her death) and the Mijareses appealed to the Court of Appeals; the CA, in a January 26, 2000 Decision (and Resolution denying reconsideration, June 19, 2000), reversed and set aside the trial court, holding the deed valid in favor of the Mijareses as purchaser...(Pro-only)
Issues:
- What is the legal status of the sale of Lot No. 4349‑B‑2 to the Spouses Mijares?
- If the sale is annullable, should annulment reach the entire contract or only the wife’s one‑half share?
- Were the Spouses Mijares purchasers...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)