GR 200274; (April, 2016) (Digest)
G.R. No. 200274 , April 20, 2016
Melecio Domingo, Petitioner, vs. Spouses Genaro Molina and Elena B. Molina, substituted by Ester Molina, Respondents.
FACTS
Spouses Anastacio and Flora Domingo, married before the effectivity of the Family Code, bought a one-half undivided portion of a parcel of land in Camiling, Tarlac, on June 15, 1951. Flora died in 1968. On September 10, 1978, Anastacio sold his interest in the land to respondent spouses Genaro and Elena Molina to answer for his debts, which sale was annotated on the Original Certificate of Title (OCT). In 1995, this interest was registered under Transfer Certificate of Title (TCT) No. 272967 in the spouses Molina’s names. In 1999, petitioner Melecio Domingo, a child of Anastacio and Flora, filed a Complaint for Annulment of Title and Recovery of Ownership. He argued the sale was void without Flora’s consent, was merely a collateral arrangement, and was attended by fraud, noting the transfer document could not be located and was annotated when Genaro Molina’s brother was the Register of Deeds. Melecio also claimed possession of the property. The spouses Molina asserted the sale was valid, that they had possessed the property and paid taxes, and that Melecio knew of the loans and sale. The Regional Trial Court (RTC) dismissed the complaint, finding Melecio failed to prove his claims and that Anastacio could dispose of the property to answer for conjugal debts. The Court of Appeals affirmed the RTC ruling, adding that Melecio’s action had prescribed.
ISSUE
1. Whether the sale of the conjugal property to the spouses Molina without Flora’s consent is valid and legal.
2. Whether fraud attended the transfer of the subject property to the spouses Molina.
RULING
The Supreme Court denied the petition, affirming the lower courts’ decisions.
1. On the validity of the sale: The sale was valid. The conjugal partnership of Anastacio and Flora was dissolved upon Flora’s death in 1968. Pending liquidation and partition, an implied co-ownership governed the conjugal properties among the surviving spouse (Anastacio) and the heirs of the deceased spouse (Flora). As a co-owner, Anastacio had the right under Article 493 of the Civil Code to freely alienate his undivided interest in the property. The annotation on the OCT specified that only Anastacio’s rights were sold. Thus, the sale transferred only Anastacio’s undivided interest to the spouses Molina, making them co-owners of the property to that extent.
2. On the presence of fraud: Melecio failed to prove by preponderant evidence that fraud attended the transfer. The factual findings of the RTC, affirmed by the CA, that the sale was genuine and not fraudulent, are conclusive and binding. The Court found no reason to deviate from these findings, as none of the exceptions to the rule on conclusiveness of factual findings were applicable. The annotation on the title and the spouses Molina’s exercise of acts of ownership (possession, payment of taxes) supported the validity of the transfer.