G.R. No. 109557 - Spouses Uy vs. Court of Appeals

Petitioner Gilda L. Jardeleza is the wife of Dr. Ernesto Jardeleza, Sr., who suffered a stroke rendering him comatose with no motor or mental faculties.
Petitioners Jose Uy and Glenda J. Uy are the son-in-law and daughter, respectively, of the incapacitated Ernesto Jardeleza, Sr.
Respondent Teodoro L. Jardeleza is the son of Ernesto Jardeleza, Sr. and brother of Glenda J. Uy.

Dr. Ernesto Jardeleza, Sr.’s medical condition rendered him incapable of managing his properties due to a stroke on March 25, 1991.
On June 6, 1991, Teodoro Jardeleza filed a petition for guardianship over Ernesto Jardeleza, Sr. before the RTC, Branch 25 of Iloilo City, citing the need to protect and manage the properties due to the latter’s incapacity.
On June 13, 1991, Gilda L. Jardeleza filed a separate special proceeding (SP No. 4691) before RTC Branch 32 to declare her husband incapacitated, assume sole administration of their conjugal properties, and seek court approval to sell a parcel of conjugal real property (Lot No. 4291) supposedly to cover mounting medical expenses.

RTC Branch 32 conducted hearings and on June 20, 1991, declared Ernesto Jardeleza, Sr. incapacitated, authorized Gilda to administer the conjugal properties solely, and approved the sale of Lot No. 4291 with improvements.
Teodoro Jardeleza opposed the proceedings and sought reconsideration and consolidation of both cases (guardianship and assumption of sole administration), arguing that summary proceedings under Article 253 of the Family Code were improperly applied and that judicial guardianship was the proper procedure. He also contested the sale price and propriety of disposition, alleging sentimental and economic value attached to the property.

Despite opposition, Gilda Jardeleza sold Lot No. 4291 to her daughter Glenda J. Uy for P8 million on July 8, 1991.
She filed an urgent motion for the court’s approval of the sale deed, which was granted on December 19, 1991, by Branch 32 (after the original trial judge inhibited herself and the case was re-raffled to Branch 28).

Teodoro Jardeleza appealed to the Court of Appeals, which on December 9, 1992, reversed the RTC decisions, declared the special proceedings and sale void for failure to observe proper procedural due process and proper application of judicial guardianship rules.
Petitioners’ motion for reconsideration was denied by the Court of Appeals on March 29, 1993.

The issue concerns the lawfulness of the assumption of sole administration and disposal of conjugal property under Article 124 of the Family Code via summary proceedings given the incapacity of Ernesto Jardeleza, Sr.
The controversy delves into the applicability of summary judicial proceedings under the Family Code and the necessity of compliance with due process safeguards, including whether judicial guardianship under the Revised Rules of Court is the proper remedy.

Whether under the circumstances of the husband’s incapacitation, the wife may assume sole administration of the conjugal property and sell conjugal real property with court approval through summary judicial proceedings under the Family Code.
Whether the proceedings before the RTC complied with procedural due process requirements.
Whether the court should have applied judicial guardianship rules under Rule 93 of the 1964 Revised Rules of Court instead of summary proceedings under Article 253 of the Family Code.
Whether the sale of Lot No. 4291 and its improvements to the wife’s children is valid and binding.