Case Summary (G.R. No. 206114)
Facts and Antecedent Proceedings
The case involves a parcel of land situated in Pulilan, Bulacan, measuring 255 square meters and forming part of the conjugal property of Jorge and Jacinta Leonardo. In March 1996, Ricardo, Jorge's father, initiated negotiations to sell the property to Dolores Alejo, leading to the execution of a "Kasunduan" on March 29, 1996, signed only by Jacinta and witnessed by Ricardo. Jorge did not consent or sign the agreement. Dolores made the down payment and subsequent payments, after which Jorge denied knowledge of the transaction and later claimed he was retracting consent. Following disputes, Jorge and Jacinta sold the property to spouses Cortez, issuing a new title in their names despite Dolores's occupancy.
The Ruling of the RTC
The Regional Trial Court (RTC) acknowledged the absence of Jorge's written consent for the sale but interpreted his subsequent actions—demanding compliance and permitting Dolores to occupy the property—as implied acceptance of the contract. It ruled in favor of Dolores, declaring the "Kasunduan" a perfected contract, recognized her ownership of the property, and canceled the titles held by the spouses Leonardo and Cortez. This ruling included obligations for Dolores to complete payments and for the spouses Leonardo to pay damages to Dolores.
The Ruling of the CA
The Court of Appeals (CA) overturned the RTC's decision, ruling that Jorge's actions constituted only a qualified acceptance of the "Kasunduan," which essentially acted as a counter-offer. It declared the contract void due to the lack of Jorge's consent and determined that Dolores, despite being a possessor in good faith, was entitled to reimbursement for her significant payments and improvements made to the property, with the CA remanding the case for further proceedings to ascertain the indemnity owed to her.
The Issues
Dolores appealed the CA ruling, arguing that the appeals by spouses Leonardo and Cortez should have been dismissed for procedural defects and contending that the "Kasunduan" was binding due to Jorge's implied consent following the dismissal of his annulment case. Furthermore, she claimed that spouses Cortez were not bona fide buyers since they were aware of her possession of the property.
The Ruling of this Court
The Supreme Court confirmed the appellate court’s decision. It upheld the principle that consent from both spouses is mandatory for the sale of conjugal property as dictated by the Family Code, noting that Jorge’s letters clearly repudiated the "Kasunduan." The Court main
...continue readingCase Syllabus (G.R. No. 206114)
Case Background
- The case involves a dispute over a parcel of land measuring 255 square meters located at Cut-cot, Pulilan, Bulacan, covered by Transfer Certificate of Title No. T-118170.
- The property was part of the conjugal property of Spouses Jorge and Jacinta Leonardo, upon which their residential house was built.
- In March 1996, Jorge’s father, Ricardo, initiated negotiations with Dolores Alejo regarding the sale of the property.
- On March 29, 1996, Jacinta executed a "Kasunduan" (agreement) with Dolores for the sale of the property for PhP500,000, with a specific payment schedule.
- The agreement was signed only by Jacinta, with Jorge not providing his signature.
Chronology of Events
- Following the execution of the Kasunduan, Dolores paid the initial down payment and subsequent amounts as stipulated in the agreement.
- Jorge communicated with Dolores, initially denying knowledge and consent to the Kasunduan and later demanding payment of the remaining balance while threatening to increase the price.
- After disputes arose, Jorge filed for ejectment and annulment of sale against Dolores, but the trial court dismissed these cases on technical grounds.
- Jorge and Jacinta subsequently sold the property to Spouses Ernesto Cortez and Priscilla San Pedro under a Deed of Absolute Sale dated September 4, 1998.
Regional Trial Court (RTC) Ruling
- The RTC recognized that the Kasunduan lacked Jorge's written consent but interpreted his actions as an acquiescence to the agreement.
- The RTC declared the Kasund