G.R. No. 82380 - Ayer Productions Pty. Ltd. vs. Capulong

Juan Ysasi (husband/petitioner) and Maria Aldecoa de Ysasi (wife/respondent) are the owners of a conjugal partnership.
Hacienda Manucao-A, located in Hinigaran, Negros Occidental, is acknowledged as a conjugal property acquired as early as 1951.
The couple also owns properties in Spain, between which they commute; the husband is more frequently in charge due to the hacienda’s management.

From 1952 to 1965, the hacienda was managed by Valentin Bilbao under the overall supervision of Juan Ysasi.
In 1965, management passed to Jon Ysasi, the son of the spouses.
In 1966, Juan Ysasi instructed the younger son, Jose Mari Ysasi, to assist Jon in managing the hacienda.

Jon Ysasi refused to allow Jose Mari to participate.
Jose Mari was also denied the position of Cashier, which had been designated by the father.

The internal dissension between the brothers escalated, contributing to the mounting tension in the family business.

In May 1967, the spouse (Maria Aldecoa) left Spain for the Philippines to address the conflict between the brothers and to investigate the hacienda’s management.

She carried a letter from Juan Ysasi to his sons and a list of inquiries regarding the hacienda.
The husband later claimed that she failed to provide a report on her findings.

In June 1967, Jon Ysasi tendered his resignation as manager in a letter addressed to his parents, which was accepted by Juan Ysasi.
Subsequently, as a result of Jon’s resignation, Juan Ysasi designated Valentin Bilbao (then residing in Spain) to take over the management.

Upon arriving in the Philippines on August 19, 1967, Bilbao encountered resistance.
Jon Ysasi refused to relinquish the hacienda, asserting that his mother had taken over administration after his resignation.

On September 5, 1967, Maria Aldecoa filed a verified petition in the Court of First Instance of Negros Occidental (Bacolod City, Branch V).

Her petition sought either the appointment of her as the administrator, a separation of property, or the appointment of a receiver pendente lite.
Her grounds centered on the husband’s inability to manage properly due to his age (77 years), visual impairment (blind left eye), alleged abandonment of the conjugal assets, and fraud.

The initial ex parte petition was granted on the very same day, though it was later set aside.
A supplemental petition was filed on September 22, 1967, requesting that if full implementation was not possible, a disinterested person (preferably the Bank of the Philippine Islands) be appointed receiver.
The procedural timeline continued with:

An answer to the petitions filed by Juan Ysasi (on October 3, 1967) which included affirmative defenses, counterclaims, and a third-party complaint against Jon Ysasi.
A move for a writ of preliminary mandatory and preventive injunction by the husband aimed at compelling the wife and son to deliver the hacienda to manager Valentin Bilbao.
Subsequent filings and responses regarding motions for reconsideration, objections from various parties, and additional pleadings surrounding the crop loan releases involving the Bank of the Philippine Islands.

On December 22, 1967, the respondent judge issued an order denying the petition for the preliminary mandatory injunction while ordering the Bank of the Philippine Islands to release crop loan lines subject to a later resolution.

The order also set conditions regarding monthly allowances and contemplated receivership of the hacienda if no serious objections were filed within ten days.
Prior to any transfer of possession, the Bank was to reimburse the wife for any expenses incurred in operating the hacienda.

The husband’s subsequent move to reconsider was rejected on January 17, 1968.
The present petition for certiorari seeks to annul the December 22, 1967 and January 17, 1968 orders and to obtain a mandatory injunction compelling the wife and Jon Ysasi to turn over possession and control of Hacienda Manucao-A to the husband.

Whether a husband, as statutory administrator of the conjugal partnership properties, may be deprived of his powers of administration solely based on mere allegations of abuse.

Is the wife's claim of fraud and abandonment sufficient to justify the removal of the husband’s administrative authority over the conjugal assets?
Does the issuance of an ex parte order appointing a receiver pendente lite, and the subsequent order for receivership, amount to an appropriate remedy under the circumstances?
Should allegations—absent conclusive evidence—be enough to disrupt the husband’s statutory rights under the Civil Code?

Whether the remedy of receivership, as applied in this case to protect the wife’s alleged rights, was proper given its extreme nature and its intended function as a provisional measure.