Title
Heirs of Ayuste vs. Court of Appeals
Case
G.R. No. 118784
Decision Date
Sep 2, 1999
Christina Ayuste contested the sale of conjugal property by her late husband, Rafael, claiming forgery. The Supreme Court upheld the sale, ruling her action barred by laches and affirming the buyer's good faith status.
heirs of ayuste
court of appeals
conjugal property
A

Case Summary (G.R. No. 118784)

Factual Background

During their marriage, Rafael and Christina Ayuste acquired a residential house and lot in Lucena City which was titled in the conjugal name of Rafael T. Ayuste, married to Christina Ayuste. Rafael managed a machine shop in Lucena where the couple kept the property records. On February 27, 1987, Rafael executed a deed of absolute sale transferring the subject lot to Viena Malabonga for P40,000; the deed bore a signature below the phrase "With my conformity" attributed to Christina. The deed was registered with the Register of Deeds of Lucena City on March 5, 1987 and a transfer certificate of title issued in respondent’s name. Rafael died on October 13, 1989. Christina later discovered the disposition during an inventory after her husband’s death and filed suit on March 2, 1990 to annul the sale, cancel the title issued to respondent, and recover damages, alleging forgery of her signature and lack of consent.

Trial Court Proceedings

The Regional Trial Court of Lucena City found that Rafael had sold conjugal property without his wife's consent and rendered judgment on June 20, 1991 annulling the deed of absolute sale, ordering restitution of possession and improvements, directing cancellation of Transfer Certificate of Title No. T-50046 and issuance of a new title in the name of plaintiff and her children subject to encumbrances, awarding respondent P258,200.00 for improvements and maintenance, and ordering respondent to account for rents from March 1990 at P2,700.00 per month. Both parties appealed the decision.

Court of Appeals Decision

The Court of Appeals reversed the trial court on January 23, 1995. It held that the wife's action for annulment was barred by laches for failure to bring it during the marriage as required by Article 173 of the Civil Code, and that respondent Viena Malabonga was a buyer in good faith and for value entitled to protection. The appellate court emphasized that registration of the deed with the Register of Deeds constituted constructive notice to the world and rendered respondent’s title indefeasible, and it concluded that the trial court erred in giving due course to the wife's action.

Issue Presented

The principal issue presented to the Supreme Court was whether petitioners (the heirs of Christina Ayuste) were entitled to annulment of the contract of sale executed by Rafael without Christina’s consent, or whether the claim was barred under Article 173 for failure to sue during the marriage and whether respondent’s title and status as a purchaser in good faith precluded relief.

Parties’ Contentions

Petitioners contended that the sale was expressly prohibited by law and therefore inexistent under Article 1409 of the Civil Code, or at least void under Article 166, because the husband alienated conjugal real property without the wife's consent; they argued that an action to declare a contract inexistent does not prescribe and that Christina could not be faulted for filing after her husband's death because she had no knowledge of the sale during his lifetime. Respondent maintained that the action should have been brought during the marriage under Article 173, that the deed had been registered and thus gave constructive notice, and that she was a buyer in good faith and for value protected by law.

Standard of Review and Scope

The Court observed that the trial and appellate courts had both found as fact that Rafael sold conjugal property without his wife's consent and that such factual findings would not be disturbed in a certiorari petition under Rule 45 because only questions of law are reviewable in that mode, absent specific exceptions not present in this case. The Court therefore confined its review to the legal question whether petitioners’ remedy was barred and whether annulment remained available.

Supreme Court’s Legal Analysis

The Court reviewed the statutory scheme. It noted that under Article 165 the husband is the administrator of the conjugal partnership but under Article 166 he cannot alienate or encumber conjugal real property without the wife's consent, subject to stated exceptions. The Court explained that the remedy for unauthorized dispositions is governed by Article 173, which permits the wife, during the marriage and within ten years from the questioned transaction, to ask the courts for annulment of any contract entered into by the husband without her consent; if she fails to exercise the right during marriage she or her heirs, after dissolution of the marriage, may demand the value of the property fraudulently alienated. The Court read the statute as plain and categorical: the annulment remedy must be invoked during the marriage.

Ruling on Timeliness and Notice

Applying the statutory rule to the facts, the Court found that the deed of sale was executed February 27, 1987, that Rafael died October 13, 1989, and that Christina filed suit on March 2, 1990. Although the suit was within ten years of the transaction, it was not brought during the marriage because the marriage had been dissolved by Rafael’s death. The Court therefore held that the action for annulment was barred by Article 173 for failure to file while the marriage subsisted. The Court further affirmed the Court of Appeals’ conclusion that registration of the deed on March 5, 1987 gave constructive notice to Christina, citi

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