Title
Mariano vs. Court of Appeals
Case
G.R. No. 51283
Decision Date
Jun 7, 1989
Esther Sanchez sued Lourdes Mariano for unpaid dresses; attachment was improperly issued. Conjugal assets were liable as Esther's business benefited the family; Quezon City Court improperly interfered in Caloocan Court’s execution process.
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Case Summary (G.R. No. 51283)

Conjugal Partnership Liability for Business Debts

  • Esther Sanchez engaged in business with the consent and approval of her husband, Daniel Sanchez.
  • Profits from Esther's business were utilized for family expenses, including children's education and household needs.
  • Lourdes Mariano's legal action against Esther was justified as it was incidental to the business.
  • The conjugal partnership of Daniel and Esther Sanchez is liable for debts incurred by Esther in her business, as the income benefited the partnership.
  • The Court of Appeals erred in ruling that the conjugal partnership was not liable for Esther's business obligations.

Jurisdictional Limitations of Courts

  • A Court of First Instance cannot restrain the execution of a judgment or decree from another court of equal jurisdiction.
  • The Quezon City Court improperly enjoined the execution of a judgment from the Caloocan Court, which is prohibited by law.
  • Daniel Sanchez's claim regarding the property being part of the conjugal partnership does not justify interference by a different court.

Proper Actions for Third-Party Claims

  • Section 17, Rule 39 of the Rules of Court allows a "third person" to vindicate their claim to property through a separate action.
  • A "proper action" must be distinct from the original case in which execution has been issued.
  • If a claim is made by a party to the original action, relief must be sought from the executing court, not a separate court.

Definition of "Stranger" in Legal Context

  • The husband of the judgment debtor (Esther Sanchez) cannot be considered a "stranger" to the case against her.
  • This principle is supported by precedent, where a spouse cannot seek to annul execution proceedings against conjugal property in a separate action.

Precedent and Res Judicata

  • The case of Rejuso v. Estipona illustrates that a party cannot seek to annul or enjoin enforcement of a judgment in a separate action if the same issues were previously adjudicated.
  • The court emphasized that related matters should be litigated within the original proceeding for consistency and efficiency.

Conclusion on Conjugal Assets and Business Obligations

  • Esther Sanchez's business activities, conducted with her husband's consent, establish the liability of conju...continue reading

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