Facts:

The case involves the petitioners Spouses Ricky Wong and Anita Chan, and the respondents Hon. Intermediate Appellate Court and Romarico Henson. The events leading to this case began on January 6, 1964, when Romarico Henson married Katrina Pineda. Despite having three children, the couple lived separately for most of their marriage, with Romarico residing in Angeles City and Katrina in Manila. On January 6, 1971, Romarico purchased a 1,787-square-meter parcel of land in Angeles City for P11,492, using money borrowed from an officemate. Meanwhile, in June 1972, Katrina entered into a consignment agreement with Anita Chan for jewelry valued at 199,895 Hong Kong dollars. When Katrina failed to return the jewelry within the agreed period, Anita demanded payment. Katrina issued a check for P55,000, which bounced due to insufficient funds, leading to a criminal charge of estafa against her. The lower court dismissed the case, ruling that Katrina's liability was civil, not crimin...

Facts:

Background:

• Romarico Henson married Katrina Pineda on January 6, 1964. They had three children but lived separately for most of their marriage.
• On January 6, 1971, Romarico purchased a 1,787-square-meter parcel of land in Angeles City for P11,492 using borrowed money.

Katrina’s Business Transaction:

• In June 1972, Katrina, while in Hongkong, entered into an agreement with Anita Chan, consigning jewelry worth HK$199,895 for sale.
• Katrina failed to return the jewelry or pay its value, leading Anita Chan to demand payment.
• Katrina issued a check for P55,000, which was dishonored. She was charged with estafa but was acquitted, as the court ruled her liability was civil, not criminal.

Civil Case for Collection:

• Anita Chan and her husband Ricky Wong filed a civil case for collection of HK$199,895 against Katrina and Romarico in the Court of First Instance of Pampanga.
• Atty. Gregorio Albino filed an answer on behalf of Katrina only, and subsequent hearings were conducted without Romarico’s representation.
• The court ruled in favor of the Wongs, ordering Katrina and Romarico to pay HK$199,895, plus interest, litigation expenses, and attorney’s fees.

Execution of Judgment:

• A writ of execution was issued, and four lots owned by Romarico (but registered under both spouses’ names) were auctioned.
• Leonardo Joson and Juanito Santos purchased the properties at the auction.

Romarico’s Action for Annulment:

• Romarico filed an action to annul the decision, writ of execution, and auction sale, claiming he was not represented in the case and that the properties were his exclusive capital.
• The lower court ruled in favor of Romarico, declaring the decision in Civil Case No. 2224 null and void as to him and ordering reconveyance of the properties.
• The Intermediate Appellate Court affirmed the decision, ruling that the properties were Romarico’s exclusive capital and could not answer for Katrina’s obligations.

Issue:

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Ruling:

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Ratio:

1. Representation in Court: Romarico was not properly represented in Civil Case No. 2224, as Atty. Albino only appeared for Katrina. Thus, the decision was void as to Romarico.
2. Conjugal vs. Exclusive Property: While the properties were presumed conjugal, there was no evidence to show that Katrina’s personal obligations were chargeable against the conjugal partnership.
3. Execution of Judgment: A purchaser at an execution sale acquires only the interest of the judgment debtor. Since Katrina had only an inchoate interest in the conjugal properties, Santos and Joson could not acquire full ownership.
4. Redemption: Santos’ redemption of the foreclosed property should be respected unless Romarico exercises his right of redemption.