G.R. No. 125172 - Spouses Guiang vs. Court of Appeals

Private respondent Gilda Corpuz and defendant Judie Corpuz are legally married since December 24, 1968, with three children: Junie, Harriet, and Jodie.
Petitioners-spouses Antonio and Luzviminda Guiang are adjoining residents and vendees in the contested transactions.

On February 14, 1983, Gilda and Judie purchased Lot 9, Block 8, (LRC) Psd-165409 in Koronadal for P14,735.00 under a conditional deed of sale.
Payment was by installment with a cancellation clause upon nonpayment of three successive installments.

In April 1988, the Corpuzes sold half of Lot 9 to the Guiangs with the latter building their house thereon.
In March 1990, while Gilda was in Manila, Judie sold the remaining half of the lot and house to Luzviminda Guiang for P30,000.00 by “Deed of Transfer of Rights” without Gilda’s consent.
On March 5, 1990, Luzviminda executed a separate sale agreement with the original vendor’s widow, Manuela Jimenez Callejo, for P9,000.00, to cure title defects.

Gilda returned on March 11, 1990, and found her children displaced; only Junie remained in the house.
The Guiangs filed a barangay trespass complaint; on March 16, 1990, an “amicable settlement” ordered Gilda and her children to vacate by April 7, 1990.
Gilda sought annulment of the settlement from the barangay captain but was referred elsewhere and received no relief.

Gilda filed suit on May 28, 1990 to declare the March 1 and March 16, 1990 instruments null and void.
On September 9, 1992, the RTC declared both the Deed of Transfer and the amicable settlement null and void, recognized Gilda’s ownership of the remaining half-lot, and ordered reimbursement to the Guiangs of P9,379.62 with legal interest.

The Guiangs appealed; the CA, on January 30, 1996, affirmed the RTC decision, citing lack of spouse’s consent under Family Code Article 124.
Reconsideration was denied on May 28, 1996.

Petitioners filed before the SC, arguing that the deed was merely voidable under Civil Code Article 1390 and was ratified by the amicable settlement.
Gilda filed her memorandum on November 17, 1997.

Whether the Deed of Transfer of Rights dated March 1, 1990 was validly executed or rendered void by lack of spousal consent.
Whether the amicable settlement of March 16, 1990 ratified the deed, rendering it merely voidable under Civil Code Article 1390.
Whether the CA erred in upholding Gilda’s ownership and possession of the remaining half-portion of the property.