GR 160708; (October, 2009) (Digest)
G.R. No. 160708 ; October 16, 2009
PATROCINIA RAVINA AND WILFREDO RAVINA, Petitioners, vs. MARY ANN P. VILLA ABRILLE, for herself and in behalf of INGRID D’LYN P. VILLA ABRILLE, INGREMARK D’WIGHT VILLA ABRILLE, INGRESOLL DIELS VILLA ABRILLE AND INGRELYN DYAN VILLA ABRILLE, Respondents.
FACTS
Respondent Mary Ann Villa Abrille and her husband Pedro acquired a parcel of land (Lot 7) during their marriage, covered by a title in both their names. Adjacent to it was a lot registered solely in Pedro’s name, acquired before the marriage. Using a loan and their joint efforts, they constructed a family home straddling both lots. In 1991, Pedro began neglecting his family and, without Mary Ann’s consent, sold the house and both lots to petitioners Patrocinia and Wilfredo Ravina. Mary Ann had expressly objected to the sale. Subsequently, Pedro, with armed CAFGU members and allegedly in connivance with the petitioners, forcibly transferred the family’s belongings and barred Mary Ann and her children from entering their home.
ISSUE
The primary issue was the validity of the sale of the conjugal property (Lot 7 and the house) executed by the husband without the wife’s consent, and the resulting liability for damages.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The sale of the conjugal lot (Lot 7) and the family home built thereon was declared null and void. The property was acquired during the marriage, making it conjugal under the Family Code. The law requires the consent of both spouses for any disposition of conjugal property. Pedro’s unilateral sale, despite Mary Ann’s known objection, rendered the sale void. The petitioners, as buyers, were not in good faith; they were notified of Mary Ann’s dissent and proceeded with the transaction. Consequently, they were ordered to reconvey the property.
Regarding damages, the Court upheld the award of moral and exemplary damages. The petitioners’ act of participating in the forcible ejection of the wife and children from their family home, causing them mental anguish and public humiliation, constituted a willful injury contrary to morals and good customs under Articles 19 and 21 of the Civil Code. They acted in bad faith, warranting solidary liability with Pedro for the damages awarded to compensate for the injury and serve as a public example.