Facts:

In the case titled "Heirs of Ignacia Aguilar-Reyes v. Spouses Cipriano Mijares and Florentina Mijares" (G.R. No. 143826), the petitioners, Heirs of Ignacia Aguilar-Reyes, contested the January 26, 2000 Decision and June 19, 2000 Resolution of the Court of Appeals (CA-G.R. No. 28464). The main parties involved were Vicente Reyes, Ignacia Aguilar-Reyes (the deceased wife), and the respondents, spouses Cipriano Mijares and Florentina Mijares. The case originated in the Regional Trial Court of Quezon City, Branch 101, concerning a dispute over Lot No. 4349-B-2, covering approximately 396 square meters.

Lot 4349-B-2 was registered under Transfer Certificate of Title (TCT) No. 205445 in the names of Vicente and Ignacia, constituting their conjugal property. Vicente and Ignacia were married in 1960 but had been separated since 1974. In 1983, Vicente sold this lot to the Mijares spouses for P40,000, despite Ignacia having no knowledge or consent to this sale. The title was ca

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Facts:

Background of the Conjugal Property

• The property in dispute is Lot No. 4349-B-2, approximately 396 square meters located in Balintawak, Quezon City, previously covered by TCT No. 205445.
• The lot, along with apartments built thereon, was acquired using funds from the spouses’ garments business and formed part of their conjugal properties.
• Vicente Reyes and Ignacia Aguilar-Reyes were married in 1960 but had been de facto separated since 1974.

The Sale Transaction and Subsequent Fraudulent Acts

• In or around 1983, Vicente Reyes allegedly sold the entire Lot No. 4349-B-2 to respondent spouses, Cipriano and Florentina Mijares, for P40,000.00 as evidenced by a Deed of Absolute Sale executed on March 1, 1983.
• Ignacia Aguilar-Reyes, who did not give her consent to the sale as required under the Civil Code, later discovered the transaction in 1984.
• Subsequent to the sale, TCT No. 205445 was cancelled and a new title (TCT No. 306087) was issued in the names of the respondent spouses.
• Vicente Reyes also filed a petition for administration and appointment of guardian, wherein he misrepresented that Ignacia had died, asserting he was the sole heir along with their minor children.
• On September 29, 1983, a court appointed Vicente as guardian of their minor children, and on October 14, 1983, the court authorized him to sell the estate of Ignacia.

Litigation Initiated by Ignacia and Interim Orders

• On August 9, 1984, Ignacia, through counsel, sent a letter demanding the return of her share in the property.
• Failing an amicable settlement, Ignacia filed a complaint for annulment of the sale on June 4, 1996, which was later amended to include Vicente Reyes as a defendant.
• The trial court initially ruled on February 15, 1990 that the sale was void as to Ignacia’s share, ordering Vicente Reyes to refund part of the proceeds and award moral damages.
• On May 31, 1990, the trial court modified its decision by declaring the sale void in its entirety, canceling the title issued to the respondent spouses, and ordering a reissue in the names of Ignacia and Vicente, besides directing refund of the full purchase price and awarding damages.

Appeal and Conflicting Decisions

• Both Ignacia (later substituted by her heirs after her demise) and the respondent spouses appealed the trial court’s decision.
• On January 26, 2000, the Court of Appeals reversed the trial court ruling, declaring the Deed of Absolute Sale valid and holding the respondent spouses as purchasers in good faith based on the alleged court approval and other evidentiary matters.
• The appellate decision further ordered Vicente Reyes to pay attorney’s fees and moral damages, but did not address remuneration for rentals collected on the apartments.

Petition for Review and Further Issues Presented

• Petitioners (the heirs of Ignacia) filed the petition for review challenging the validity of the sale by contending that the lack of the wife’s consent makes the transaction voidable.
• The petition raises several factual and legal controversies, including the timing and validity of the sale, the extent of the annulment (whether it should apply solely to Ignacia’s share or to the entire sale), and whether the respondent spouses were indeed purchasers in good faith.
• Evidence such as discrepancies in the alleged death certificate of Ignacia and prior agreements (dating as far back as November 25, 1978) were presented to challenge the good faith of the respondents.

Issue:

What is the legal status of the sale of Lot No. 4349-B-2, given that it was executed without the wife’s (Ignacia’s) consent as required by the Civil Code?

• Is the transaction voidable or void from the outset?
• What are the implications of the contractual fraud and misrepresentation by Vicente Reyes regarding Ignacia’s status?

Assuming the transaction is voidable, should the annulment be applied only to the share of the wife in the conjugal property or to the entire sale?

• How does the law address the annulment of contracts involving conjugal property?
• What supporting doctrine or case law guides this determination?

Are the respondent spouses (Cipriano and Florentina Mijares) considered purchasers in good faith?

• Did the circumstances surrounding the sale, including the questionable death certificate and prior agreements, place the respondents on notice of the lack of consent?
• Does the evidence suggest that they had adequate opportunity to ascertain the true status of the property and Ignacia’s consent?

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)