A.C. No. 3319 - Ui vs. Bonifacio

Willem Beumer (petitioner), a Dutch national, married Avelina Amores (respondent), a Filipina, on March 29, 1980.
The marriage was annulled by the Regional Trial Court (RTC) of Negros Oriental, Branch 32, on November 10, 2000, due to petitioner’s psychological incapacity under Article 36 of the Family Code.
Following annulment, petitioner filed a Petition for Dissolution of Conjugal Partnership on December 14, 2000, seeking distribution of certain properties acquired during the marriage.

Lot 1, Block 3 of consolidated survey of Lots 2144 & 2147, Dumaguete Cadastre (252 sq.m.), TCT No. 22846, with a residential house.
Lot 2142, Dumaguete Cadastre (806 sq.m.), TCT No. 21974, with a residential house.
Lot 5845, Dumaguete Cadastre (756 sq.m.), TCT No. 21306.
Lot 4, Block 4 of consolidated survey of Lots 2144 & 2147, Dumaguete Cadastre (45 sq.m.), TCT No. 21307.

1/7 of Lot 2055-A, Dumaguete Cadastre (2,635 sq.m., equivalent conjugal partnership area 376.45 sq.m.), TCT No. 23567.
1/15 of Lot 2055-I, Dumaguete Cadastre (360 sq.m., equivalent conjugal partnership area 24 sq.m.), TCT No. 23575.

Respondent claimed that except for the two houses on Lots 1 and 2142, all properties were purchased with her personal funds or were inherited.
Submitted a joint affidavit with petitioner attesting she used her own money for Lot 2142 and its improvements.
Denied the formation of any conjugal partnership over the other claims.
Sought dismissal of petition and recovery of attorney’s fees and litigation expenses.

Petitioner testified that funds from his Dutch government disability benefits were used to purchase Lots 1, 2142, 5845, and 4, as respondent had insufficient income.
He challenged the validity of their joint affidavit under Article 89 of the Family Code.
Respondent maintained ownership through her personal earnings and inheritance, citing sales of jewelry and products.
After the annulment petition, petitioner moved to the second house and transferred certain personal properties valued at P500,000.

Dissolved the conjugal partnership based on prior annulment of the marriage.
Declared all parcels of land covered by the subject TCTs as respondent’s paraphernal properties, emphasizing that:

Petitioner, as a foreigner, could not legally acquire private land in the Philippines except via inheritance.
Petitioner’s attempt to purchase land contravened constitutional prohibition.

Declared tools and equipment brought by petitioner as his exclusive property.
Declared the two houses on Lots 1 and 2142 as co-owned by petitioner and respondent (since foreigners may own buildings) and ordered partition of these properties.
Denied petitioner’s claim for reimbursement for purchase funds based on inequity and unclean hands doctrine.
Denied counterclaim for attorney’s fees and moral damages as lacking merit.

Affirmed the RTC decision in toto.
Emphasized petitioner’s knowledge of constitutional prohibition against foreign ownership of private lands.
Denied petitioner’s claim for reimbursement, given his attempt to circumvent the law.

Petitioner assailed the CA ruling, arguing error in denying his claim for reimbursement or share in the purchased properties despite his capital contribution.

Whether a foreigner (petitioner) who knowingly purchased Philippine private land in violation of the constitutional prohibition can recover reimbursement or any monetary claim from a former spouse for the purchase price paid.
Whether equity or unjust enrichment principles apply to grant petitioner reimbursement despite his awareness and admission of the constitutional ban on foreign ownership of land.
Whether the properties should be considered part of the conjugal partnership subject to distribution or belong solely to respondent.