G.R. No. 70168-69 - Molina vs. People

The spouses, Amadeo and Estela Costuna, during their marriage acquired three parcels of land in San Francisco del Monte, Quezon City, covering an aggregate of approximately 599 square meters.
The lots were registered in the name of Amadeo Costuna under Transfer Certificates of Title Nos. 1235, 18118, and 24365.

On November 8, 1976, Amadeo executed his last will and testament at the age of 68, designating provisions regarding his estate.
Following the execution of the will, marital problems surfaced between Amadeo and Estela, contributing to a deteriorating conjugal relationship.

In November 1977, Amadeo sustained third degree burns on his legs and was treated at various hospitals, including Bonifacio Maternity Clinic and Bago-Bantay General Hospital.
Amidst his illness, Amadeo was persuaded by relatives to travel to Samar for the signing of documents regarding his properties there, and he subsequently stayed with his sister, leading to a prolonged separation.
The prolonged absence of Amadeo from the conjugal home resulted in a custody feud, prompting Estela to file a petition for habeas corpus on June 18, 1978, while Amadeo also filed an action for partition on June 23, 1978.

Amid demands for partition and after repeated requests for Estela’s consent, Amadeo was compelled to execute a deed of sale on July 10, 1978, transferring his undetermined one-half share in the conjugal property to Laureana Domondon.
The sale was motivated by Amadeo’s pressing need to cover hospital and medical expenses, as his condition required urgent financial resources.

Amadeo’s death on November 5, 1978, rendered the earlier petitions for habeas corpus and partition moot, leading to new proceedings.
In the ensuing Special Proceedings No. Q-26351 instituted by Estela before the Court of First Instance, issues regarding the allowance of the will and the issuance of Letters of Administration (or more correctly, letters testamentary) were resolved in favor of Estela.
Respondent Laureana Domondon, asserting her right to a one-half share based on the deed of sale, instituted an action in the Regional Trial Court (RTC, Branch XCVIII, Quezon City, docketed as Q-34527) seeking to compel Estela to grant her conformity by affixing her signature to the deed.

The trial court ruled in favor of Domondon, holding that Estela’s unreasonable withholding of consent was sufficient to compel her signature, under the provisions of Article 166 of the New Civil Code.
The Court of Appeals, in CA-G.R. CV No. 10948, affirmed the trial court’s ruling, finding that the sale was valid since the proceeds were dedicated to covering Amadeo’s hospital and medical expenses.

Estela Costuna, the petitioner, filed a petition for review on certiorari challenging the ruling of the Court of Appeals on the basis that a question of substance had been erroneously decided.
The petitioner asserted that the deed of sale was null and void due to the alleged simulation, lack of informed consent, questionable circumstances surrounding Amadeo’s signature, and issues regarding the adequacy of consideration.
Additionally, she contended that the hospital and medical expenses of Amadeo should not have been charged to the conjugal partnership given his abandonment of the conjugal home.

Whether the deed of sale executed by Amadeo in favor of Laureana Domondon, disposing of his one-half share in the conjugal partnership without the wife’s consent, is valid or null and void.

Whether the circumstances surrounding the execution of the deed, including the alleged incapacity and questionable signature of Amadeo, render the transaction simulated or spurious.
Whether the lack of Estela Costuna’s consent, deemed unreasonable in light of repeated demands and the exigent circumstances, invalidates the transaction.
Whether the hospital and medical expenses incurred by Amadeo are chargeable to the conjugal partnership, notwithstanding the fact that Amadeo had also abandoned the conjugal home.
The proper application of Articles 161, 166, 167, and 171 of the New Civil Code in determining the validity of the transaction and the resultant liability of the conjugal partnership.