Case Digest (G.R. No. 196735)
Facts:
Margaret Maxey assisted by Santiago Magbanua; Florence Maxey assisted by Ofrecinio Santos; and Lucille Maxey v. The Honorable Court of Appeals and the Spouses Beato C. Macayra and Alacopue Monday, G.R. No. L-45870, May 11, 1984, the Supreme Court First Division, Gutierrez, Jr., J., writing for the Court (Teehankee, Escolin, Relova and De la Fuente, JJ., concurring; Plana, J., reserves his vote; Melencio-Herrera, J., no part).The petitioners are the children and heirs of Melbourne Maxey and Regina Morales Maxey (petitioners’ parents); the private respondents are the purchasing spouses Beato C. Macayra and Alacopue Monday. The dispute concerns several parcels of land acquired in 1911–1912 by Melbourne during his cohabitation with Regina, their disposition by sale in 1953, and whether those lands were common property of the informal union (and thus partly the property of Regina and her heirs).
In 1962 the heirs (petitioners) sued in the Court of First Instance of Davao to annul the 1953 deeds of sale executed by Melbourne (through his attorney-in-fact, Julia Pamatluan Maxey) in favor of the private respondents, to recover possession of the lands, and for damages. The trial court applied Article 144 of the Civil Code and declared the sales null and void, ordered reconveyance, awarded the use value, P500 actual damages and P3,000 attorney’s fees; the defendants’ counterclaim was dismissed.
The Court of Appeals reversed, finding the parcels to be the exclusive properties of Melbourne Maxey, upholding the 1953 sales as valid, and rejecting the contention that the parents had married “in military fashion” in 1903. The appellate court interpreted “joint efforts” narrowly as monetary contribution and relied on precedents (notably Aznar et al. v. Garcia) to treat Article 144 as nonretroactive so as not to prejudice vested rights.
The petitioners brought a petition for review on certiorari to the Supreme Court cha...(Subscriber-Only)
Issues:
- Did Melbourne Maxey and Regina Morales marry in 1903 (by “military fashion”), or only in 1919?
- Should Article 144 of the Civil Code be applied to the lands sold in 1953, i.e., is Article 144 retroactive so as to affect vested or acquired rights arising under the prior law?
- Were the parcels acquired in 1911–1912 common property by reason of the spouses’ “joint efforts” (including household management), so that one-half belonged to ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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