G.R. No. 164584 - Matthews vs. Taylor

On June 30, 1988, British subject Benjamin A. Taylor married 17-year-old Filipina Joselyn C. Taylor.
On June 9, 1989, Joselyn purchased a 1,294 sqm lot in Manoc-Manoc, Boracay Island, for ₱129,000, allegedly financed by Benjamin.

Joselyn and Benjamin used Benjamin’s funds to improve the lot into the Admiral Ben Bow Inn.
Permits and licenses for the resort were issued in the name of Ginna Celestino (Joselyn’s sister) due to Joselyn’s minority at the time.

On June 8, 1992, Joselyn executed a Special Power of Attorney in favor of Benjamin authorizing him to manage or dispose of the Boracay property.
On July 20, 1992, Joselyn (lessor) and Philip Matthews (lessee) executed a 25-year lease of the property at ₱12,000/year; Benjamin signed the lease as a witness.

Benjamin filed for nullity of the lease, claiming (a) ownership rights by funding acquisition and improvement and (b) lack of his consent as spouse.
RTC default judgment (March 14, 1994) declared lease void; CA set aside the default, allowed Matthews to answer, and remanded for further proceedings (CA-G.R. SP No. 34054).
After trial on the merits, RTC (June 30, 1997) again declared the lease null and void, awarded Benjamin ₱16,000 (unrealized income) and ₱20,000 (attorney’s fees).
CA (Dec. 19, 2003 Decision; July 14, 2004 Resolution) affirmed the RTC, holding that Joselyn lacked Benjamin’s consent and that Benjamin’s signature as witness did not constitute consent.
Philip Matthews petitioned to the Supreme Court for review on certiorari.

Whether the marital consent of Benjamin Taylor was required for Joselyn to validly lease the Boracay property.
Whether Benjamin, as an alien, had ownership or conjugal/community property rights over the Boracay property, and thus capacity to annul the lease.
Whether the Agreement of Lease is vitiated by lack of Benjamin’s consent or by alleged community property regime.
Whether constitutional prohibitions on alien land ownership bar Benjamin’s claim to nullify or impugn the lease.