Case Digest (G.R. No. 185960)
Facts:
Belinda Alexander filed a Petition for Review on Certiorari under Rule 45 assailing the October 26, 2020 Decision and March 5, 2021 Resolution of the Court of Appeals (CA) in CA-G.R. CV No. 110958. The case arose from a Complaint for Annulment of Documents with damages filed by Spouses Jorge and Hilaria Escalona before the Regional Trial Court (RTC) of Olongapo City, Branch 72, docketed as Civil Case No. 342-0-2005. The Spouses, married on November 14, 1960, acquired two unregistered lots (Lot 1 and Lot 2) in Barangay Sta. Rita, Olongapo City. On June 16, 1998, Jorge executed a Waiver and Quitclaim of Lot 1 in favor of his illegitimate son, Reygan Escalona, without written consent from Hilaria. On July 28 and August 8, 2005, Reygan renounced rights over Lot 1 and Lot 2, respectively, in favor of Belinda, and on August 10, 2005, sold both parcels to her for P1,600,000.00. Spouses Escalona invoked lack of Hilaria’s consent and alleged fraud, while Belinda pleaded prescription, lacCase Digest (G.R. No. 185960)
Facts:
- Marriage and Conjugal Property
- Spouses Jorge and Hilaria Escalona married on November 14, 1960 under the Civil Code; regime: conjugal partnership of gains.
- They acquired unregistered Lot Nos. 1 and 2 (100,375 sqm) in Brgy. Sta. Rita, Olongapo City.
- Dispositions without Wife’s Consent
- June 16, 1998: Jorge waived his rights over Lot No. 1 in favor of his illegitimate son Reygan Escalona (Reygan) without Hilaria’s consent.
- July 28, 2005: Reygan relinquished any claim in Lot No. 1 to petitioner Belinda Alexander (Belinda).
- August 8, 2005: Reygan transferred Lot No. 2 to Belinda by Deed of Renunciation and Quitclaim.
- August 10, 2005: Reygan sold Lots 1 and 2 to Belinda for ₱1,600,000 via Deed of Absolute Sale.
- Procedural History
- September 5, 2005: Spouses Escalona filed RTC Civil Case No. 342-0-2005 for annulment of instruments and damages.
- Belinda moved to dismiss on laches, prescription, and good-faith purchaser grounds; filed cross-claim vs. Reygan and third-party complaint vs. his mother. Reygan denied fraud.
- February 20, 2017: RTC dismissed complaint as time-barred (Civil Code Art. 1391, 4-year period); upheld validity of waivers and quitclaims; awarded Belinda possession, damages, and fees.
- October 26, 2020: CA reversed; held Lots 1 & 2 conjugal properties; transactions void for lack of Hilaria’s consent under Family Code Art. 124; actions imprescriptible; rejected good-faith defense.
- March 5, 2021: CA denied Belinda’s motion for reconsideration.
- Belinda elevated case to the Supreme Court via Petition for Review on Certiorari.
Issues:
- Applicable Law and Timing
- When a marriage was under the Civil Code but a conjugal-property disposition occurred after the Family Code’s effectivity, which law governs the status of the contract?
- Should the prescriptive period be measured from date of marriage or date of the disposition?
- Prescription and Remedies
- Are actions to nullify such dispositions barred by prescription?
- What remedies are available to the transferee and the spouses?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)