Case Digest (G.R. No. 256141)
Facts:
Belinda Alexander v. Spouses Jorge and Hilaria Escalona, and Reygan Escalona, G.R. No. 256141, July 19, 2022, Supreme Court En Banc, Lopez, J., writing for the Court.Petitioner Belinda Alexander bought two unregistered parcels (Lot Nos. 1 and 2) from respondent Reygan Escalona in August 2005 for P1,600,000.00; Reygan had earlier (June 16, 1998) received a Waiver and Quitclaim over Lot No. 1 from his father, respondent Jorge Escalona, who was married to respondent Hilaria Escalona since November 14, 1960. Reygan’s transfers to Belinda consisted of a relinquishment/quitclaim (Lot No. 1, July 28, 2005), a Deed of Renunciation and Quitclaim (Lot No. 2, August 8, 2005), and a Deed of Absolute Sale (August 10, 2005). Spouses Escalona claim Jorge had no authority to alienate conjugal property without Hilaria’s written consent and notified Belinda in a barangay conciliation on August 5, 2005.
On September 5, 2005 Spouses Escalona filed before the Regional Trial Court (RTC), Olongapo City, Civil Case No. 342-0-2005, a complaint for annulment of documents with damages against Belinda and Reygan alleging lack of consent, fraud and that Lot Nos. 1 and 2 were conjugal property. Belinda moved to dismiss on laches and prescription and pleaded good faith; Reygan denied fraud and asserted he already owned Lot No. 1.
By Decision dated February 20, 2017, the RTC (Judge Paradeza) dismissed Spouses Escalona’s complaint as time-barred and upheld the waivers and sale, ordering the plaintiffs to vacate the land and pay damages to Belinda. The RTC’s denial of reconsideration was entered on August 22, 2017. Spouses Escalona appealed to the Court of Appeals (CA) in CA-G.R. CV No. 110958.
In a Decision dated October 26, 2020, the CA reversed the RTC, holding Lots 1 and 2 were conjugal property, the contracts void for lack of Hilaria’s consent under Article 124, Family Code, and that actions to nullify were imprescriptible under Article 1410, Civil Code (because the transactions involved unregistered land and were void). The CA also found Belinda not a buyer in good faith and remanded to declare the documents void. Belinda’s motion for reconsideration was denied by CA resolution on March 5, 2021.
Belinda then filed this Petition for Review on Certiorari under Rule 45 of the Rules of Court, assailing the CA’s October...(Pro-only)
Issues:
- Procedural: When spouses were married during the Civil Code but the questioned alienation or encumbrance occurred after the Family Code took effect, does the applicable law turn on the date of marriage or on the date of the transaction?
- Substantive: If the challenged dispositions of conjugal property were made without the other spouse’s consent, are those transactions void or merely voidable, and what are the consequences for prescription (i.e., is the action imprescriptible)?
- Substantive: Was petitioner Belinda a buyer in good faith entitled to retain ownership of Lots Nos. 1 and ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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