G.R. No. 265651 - TJ Lending Investors, Inc. vs. Spouses Ylade

TJ Lending Investors, Inc. (TJ Lending), represented by its Collection Manager Eduardo M. Punzalan, filed a Complaint for sum of money (Collection Case) against several spouses, including Spouses Nenita GenerosaA-Cubing and Egmedio Cubing (Spouses Cubing), Roberto Bueno and Elimar Generosa-Bueno, and Lita Generosa-Ylade and Arthur Ylade (Spouses Ylade).
The complaint was dismissed against Spouses Roberto and Arthur Ylade in the Collection Case due to lack of evidence.

The Spouses Cubing obtained a loan of PHP 940,190.94 from TJ Lending evidenced by a promissory note.
Lita Ylade, sister of Nenita Generosa-Cubing, executed a co-maker statement, making her solidarily liable for the loan repayment.
The Spouses Cubing defaulted prompting TJ Lending to file the Collection Case.

RTC Branch 173 ruled that the Spouses Cubing and Lita are liable for the loan debt, ordering payment with interest, attorney's fees, and costs.
The action was dismissed against Arthur Ylade and others since they were not signatories or liable debtors.

To satisfy the judgment debt, the Sheriff attached and levied upon a real property in Tondo, Manila, covered by Transfer Certificate of Title (TCT) No. 170488 registered solely in the name of Arthur Ylade, married to Lita Ylade.
The property was publicly auctioned; TJ Lending was the highest bidder.
The property was not redeemed within one year, leading to the issuance of a Final Deed of Sale in favor of TJ Lending.

Arthur filed a Motion to Nullify the levy, execution sale, and to cancel the Certificate of Sale and Final Deed of Sale, asserting exclusive ownership of the property.
He contended the execution sale was invalid as he was not a judgment debtor and owned the property exclusively.
RTC Branch 173 denied his motion citing Arthur was declared in default and failed to redeem the property.

TJ Lending demanded the surrender of the Owner's Duplicate of TCT No. 170488 which was refused by the Spouses Ylade.
TJ Lending filed a Petition for Surrender of Title before RTC Branch 4, arguing the property must be surrendered following the final deed of sale.
Arthur opposed, insisting the property was acquired before marriage and was his exclusive property, and challenged the propriety of the execution sale.

The RTC granted the petition, finding the property presumed conjugal under Article 160 of the Civil Code as it was acquired during the marriage.
Arthur failed to overcome the presumption; the property could be attached and sold to satisfy the judgment debt against Lita.
Arthur's motion for reconsideration was denied.

The CA reversed the RTC judgment, dismissing the Petition for lack of merit.
CA held that the mere fact of husband's marriage on TCT is descriptive and not conclusive of conjugal ownership.
It found insufficient evidence to prove the property was acquired during marriage.
The CA ruled that executing sale of conjugal property is proper only if the debt redounded to the benefit of the family, which was not proven.

TJ Lending filed a Petition for Review on Certiorari before the Supreme Court challenging the CA decision.
The Court directed Arthur Ylade to comment, but none was filed.

Whether the subject property covered by TCT No. 170488 is conjugal property of Spouses Arthur and Lita Ylade or exclusively Arthur's.
Whether the execution sale of the property to satisfy the judgment debt against Lita in the Collection Case was proper and valid.
Whether the CA erred in reversing the RTC's decision granting TJ Lending's Petition for Surrender of Title.