Case Digest (G.R. No. 253450) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
This case involves Lani Nayve-Pua as the petitioner and Union Bank of the Philippines as the respondent. The underlying dispute concerns a real estate mortgage (REM) over a property in Diliman, Quezon City, originally purchased in March 1978 by Stephen Pua, prior to his marriage to Lani in July 1983. Lani and Stephen lived together as husband and wife starting in December 1975 and had four children. The property was solely titled in Stephen's name, who was a legal age Filipino single at the time of purchase. After the marriage, their property regime was conjugal partnership of gains under the Civil Code. In January 2004, Lani learned the property was mortgaged and foreclosed by Union Bank in favor of Spouses Cromwell and Catherine Uy, relatives of Stephen. Lani alleged forgery of her signature on the Special Power of Attorney (SPA) which authorized the mortgage, denying any consent. Union Bank claimed the mortgage was valid since the property was Stephen's exclusive property, ac Case Digest (G.R. No. 253450) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Parties
- Lani Nayve-Pua (Petitioner) lived with Stephen Pua (her partner) since December 1975, cohabiting as husband and wife without being legally married.
- They have four children born during the cohabitation period before their official marriage in July 1983.
- In March 1978, Lani and Stephen bought a property in Diliman, Quezon City, registered under Stephen's name as "single".
- The house built on the property became their family home.
- Mortgage and Foreclosure
- In January 2004, Lani discovered the property was mortgaged by Spouses Cromwell and Catherine Uy (related by family to Stephen) to Union Bank of the Philippines (Union Bank) as collateral for a loan.
- The Uys defaulted on the loan, leading to foreclosure and public auction of the property which Union Bank won.
- Legal Action and Claims
- Lani filed a complaint to annul the real estate mortgage (REM), foreclosure, and certificate of sale, denying consent to the mortgage, asserting forgery of her signature on a Special Power of Attorney (SPA) used by the Uys.
- Union Bank argued that the property was Stephen's exclusive property, acquired before marriage and hence not conjugal property, and that the notarized SPA bore valid signatures.
- Court Proceedings
- The Regional Trial Court (RTC) dismissed Lani's complaint, holding the property was Stephen's separate property under the conjugal partnership of gains regime, given it was acquired prior to marriage and registered under his sole name.
- The Court of Appeals (CA) affirmed this decision, emphasizing the prima facie presumption under Article 147 of the Family Code is rebuttable and that Lani failed to demonstrate exclusive cohabitation as husband and wife or contribution to the property's acquisition.
- Lani moved for reconsideration, which was denied.
- Lani elevated the case to the Supreme Court.
Issues:
- Whether the real estate mortgage and subsequent foreclosure by Union Bank on the property should be annulled.
- Whether Lani's consent was necessary and if its purported absence or forgery affects the validity of the mortgage.
- Whether the property is conjugal or Stephen's exclusive property.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)