Case Digest (G.R. No. 260912)
Facts:
On September 5, 2003, Luis G. Anson sued Jo-Ann Diaz-Salgado and Dr. Gerard C. Salgado (Spouses Salgado), along with Maria Luisa Anson-Maya and Gaston Maya (Spouses Maya), in the Pasig City RTC (Branch 155) by filing Civil Case No. 69611 to annul three Unilateral Deeds of Sale dated January 23, 2002 and a Deed of Extra-Judicial Settlement of Estate dated October 25, 2002. Luis alleged that he and the late Severina de Asis-Anson were validly married on December 28, 1966, without any marriage settlement, so all properties they acquired belonged to their conjugal partnership. Unknown to him, Severina purportedly sold three parcels covered by TCT Nos. 20618, 60069, and 5109 to Jo-Ann and Maria Luisa later secured titles over three other parcels. Claiming divestment of his conjugal share and inheritance, Luis presented a certified copy of his marriage contract and other documents. The Spouses Salgado countered that no valid marriage existed between Luis and Severina, as they only livCase Digest (G.R. No. 260912)
Facts:
- Parties and Properties
- Petitioners: Jo-Ann Diaz-Salgado and Dr. Gerard C. Salgado (Spouses Salgado)
- Respondent: Luis G. Anson (Luis)
- Properties at issue: Six parcels in San Juan, Metro Manila, originally under TCT Nos. 20618/T-104, 60069/T-301, 5109/T-26, 8478-R/T-43, 44637/T-224-II, and 8003/T-41 (now re-numbered).
- Underlying Transactions
- Jan. 23, 2002 – Severina de Asis (deceased spouse of Luis) executed three Unilateral Deeds of Sale conveying TCT Nos. 20618, 60069, 5109 to Jo-Ann; Jo-Ann secured new titles.
- Sep. 21, 2002 – Severina died.
- Oct. 25, 2002 – Maria Luisa Anson-Maya (daughter of Severina by a previous relationship) executed an Extra-Judicial Settlement adjudicating herself sole heir of TCT Nos. 8478-R, 44637, 8003; obtained new titles.
- Procedural History
- Sept. 5, 2003 – Luis filed Civil Case No. 69611 in RTC Pasig, seeking annulment of the three Unilateral Deeds of Sale and the Extra-Judicial Settlement, alleging (a) he was surviving spouse of Severina married Dec. 28, 1966; (b) properties were conjugal; (c) transfers occurred without his consent, depriving him of conjugal and inheritance rights.
- Spouses Salgado’s defense: Denied valid marriage (no license), invoked two Partition Agreements (Nov. 1980, Apr. 1981) dividing co-owned properties, claimed Severina’s sole ownership of disposed assets.
- Spouses Maya’s defense: Mirrored Spouses Salgado, presented Certificate of No Record of Marriage.
- Feb. 16, 2006 – RTC denied Spouses Salgado’s and Maya’s demurrers to evidence.
- July 23, 2007 – RTC Decision declared marriage valid, annulled Unilateral Deeds of Sale and corresponding new titles.
- Nov. 17, 2008 – RTC Decision set aside Maria Luisa’s settlement and cancelled her new titles.
- Appeals: Spouses Maya’s appeal terminated by compromise; Spouses Salgado’s appeal dismissed by CA Decisions (Aug. 6, 2012; Nov. 26, 2012).
- July 27, 2016 – Supreme Court granted Luis’s petition for review on certiorari under Rule 45.
Issues:
- Is the marriage of Luis and Severina valid despite the marriage contract’s absence of a license and its reference to Article 77 (exceptional character)?
- Who bears the burden of proving the existence or non-existence of a marriage license when the marriage contract itself states none was exhibited?
- Is the 1980 Partition Agreement between Luis and Severina valid and binding on their property relations given the marriage is void?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)