Case Digest (G.R. No. 164584)
Facts:
Philip Matthews v. Benjamin A. Taylor and Joselyn C. Taylor, G.R. No. 164584, June 22, 2009, Supreme Court Third Division, Nachura, J., writing for the Court. Petitioner Philip Matthews sought review of the Court of Appeals’ December 19, 2003 Decision and July 14, 2004 Resolution in CA-G.R. CV No. 59573, which had affirmed the Regional Trial Court (RTC), Branch 8, Kalibo, Aklan, June 30, 1997 judgment declaring null and void a 25‑year lease of a Boracay lot and awarding damages to respondent Benjamin Taylor.Respondent Benjamin A. Taylor (a British subject) married respondent Joselyn C. Taylor (a Filipina) on June 30, 1988. In 1989 Joselyn purchased a 1,294 sq. m. lot in Manoc‑Manoc, Boracay, evidenced by a deed of sale in her name; Benjamin allegedly financed the purchase and assisted in improvements that became a resort. Licenses were issued in the name of Joselyn’s sister because Joselyn was a minor at the time. In June 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 petitioner Matthews (lessee) executed a notarized Agreement of Lease for 25 years with annual rent of P12,000; Matthews took possession and operated the resort. Benjamin sued Joselyn and Matthews for declaration of nullity of the lease, claiming (a) he provided the funds for acquisition and improvements and (b) Joselyn could not validly dispose of the property without his marital consent. Joselyn and Matthews were initially declared in default and the RTC entered judgment nullifying the lease; the Court of Appeals (in CA‑G.R. SP No. 34054) set aside that default judgment, allowed Matthews to answer, and remanded for further proceedings.
At trial Matthews asserted he acted in good faith, that Joselyn appeared to be the owner, and that Benjamin’s signature as a witness on the last page of the lease indicated knowledge and implied consent. The RTC on June 30, 1997 again declared the lease null and void, awarded Benjamin P16,000 as unrealized income and P20,000 attorney’s fees, finding the Boracay lot community property and that Benjamin’s signature only on the last page did not prove consent. The Court of Appeals affirmed on December 19, 2003, reasoning that the parties should have used the phrase “with my consent” if Benjamin intended to consent, and that the SPA made prior participation by Benjamin unnecessary — reinforcing lack of consent and invalidity of the lease.
Matthews filed a petition for review on certiorari to the Supreme Court (Rule 45), urging among other grounds that marital consent was not required or was given; that the lot was Joselyn’s exclusive property; that th...(Pro-only)
Issues:
- Did respondent Benjamin A. Taylor, an alien, have the legal capacity or right to attack the lease executed by his Filipino wife by seeking its nullification?
- If Benjamin had such capacity, was the Agreement of Lease of July 20, 1992 invalid for lack of his marital consent?
- Were the lower courts correct to treat the Boracay lot as conjugal/community property and apply Article 96 of the Family Code to invalidate the lease?
- Did the notarization of the lease create a presumption of regularity that the courts below should have honored to sustain the lease?
- Was the Court of Appeal...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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