G.R. No. 156125 - Munoz, Jr. vs. Ramirez

Francisco L. Gonzales (petitioner) and Erminda F. Gonzales (respondent) began living together as husband and wife in March 1977.
They were married on February 4, 1979, after cohabiting for two years.
The union produced four children: Carlo Manuel, Maria Andres, Maria Angelica, and Marco Manuel.

On October 29, 1992, respondent filed a complaint for the annulment of their marriage, coupled with a prayer for support pendente lite.
The complaint alleged that petitioner was psychologically incapacitated for marital obligations, citing acts of beating, humiliation, and denial of marital love and sexual comfort.
Respondent sought, in addition to a nullity declaration and annulment of the conjugal partnership of gains, the dissolution of the partnership and appropriate division of properties acquired during the union.

Petitioner alleged that it was respondent who was psychologically incapacitated.
He claimed exclusive ownership of properties purportedly acquired during the marriage.

Claimed that she managed their pizza business and maintained that she contributed significantly (80% management) to its operations.
Contended that all income from the business belonged to the conjugal partnership.

Testimonies and evidences showed that petitioner beat respondent without justifiable reason and in the presence of witnesses and children.
Petitioner was further alleged to have suffered from satyriasis, a personality disorder marked by excessive sexual desire and indiscriminate womanizing.

Both parties submitted lists and valuations of properties acquired during their union, which included real estate and personal property (vehicles).
Items disputed ranged from houses, lots, and condominiums to various vehicles, with differing valuations asserted by each party.
The trial court, in its decision rendered on February 12, 1997, declared the marriage null and void ab initio and ordered the dissolution of the conjugal partnership of gains with a detailed division of properties.
Among the orders were:

Award of custody of children with visitation rights.
Payment of monthly support.
Specific division of real and personal properties between the petitioner and respondent.
A directive that the party in possession of the property execute documents transferring title accordingly.

Petitioner appealed to the Court of Appeals, contesting the manner in which properties were divided.
Petitioner did not contest the decision ruling his marriage void ab initio.
The Court of Appeals affirmed the trial court’s decision in its ruling dated April 2, 2003.
Petitioner’s motion for reconsideration was denied in an Order dated July 23, 1997, leading to the present petition for review on certiorari.

Whether the Court of Appeals erred in its ruling that the conjugal properties should be divided equally between the parties.

Determination of the correct application of Article 147 of the Family Code in the context of a void marriage and the resulting property relations.
The evidentiary basis for presuming joint acquisition of properties acquired during the marriage.
Whether the contributions of each party—both in monetary and non-monetary terms (such as managing the business and care of the family)—merit an equal distribution of the conjugal property.