G.R. No. 246445 , March 2, 2021
Spouses Eulalio Cuena and Flora Bonifacio Cuena, Petitioners, vs. Spouses Epifanio and Veronica Bautista, Spouses Rizaldo and Anacita Bautista, Spouses Dionilo and Mary Rose Bautista, Spouses Roel and Jessibel B. Sanson, and Spouses Calixto and Mercedita B. Fernando, Respondents.

FACTS

The dispute involves conflicting claims of ownership over a parcel of land. Lot No. 2836 was previously co-owned by Luis Bonifacio (married to Juana Toribio) and Isidro Bonifacio (married to Victoria Falcatan). In 1961, petitioners Spouses Eulalio and Flora Bonifacio Cuena (Flora is the daughter of Luis and Juana) bought Isidro’s pro indiviso share, as reflected in an Escritura de Venta dated October 23, 1961 (first sale). TCT No. T-20,676 was issued on April 13, 1967, in the names of Luis and Eulalio.
Prior to this issuance, Eulalio supposedly sold his and Flora’s share to Flora’s father, Luis, via an Escritura de Venta dated December 4, 1963 (second sale), without Flora’s consent. This second sale was registered on the same day TCT No. T-20,676 was issued, leading to its cancellation and the issuance of TCT No. T-20,677 solely in the name of Luis.
In 1977, Luis allegedly sold the property to respondents via a Deed of Absolute Sale dated August 12, 1977 (third sale). TCT No. T-20,677 was cancelled, and TCT No. T-49,239 was issued in the name of Spouses Epifanio and Veronica Bautista. Respondents took possession, built improvements, and later donated the property to their children. Petitioners filed a complaint in 2008 for recovery of shares, possession, and declaration of nullity of the second sale and donation, claiming the second sale was invalid for lack of Flora’s consent and that Luis never sold the property to respondents.
The Regional Trial Court (RTC) granted the complaint, declaring the second sale void for lack of spousal consent, and consequently voided all subsequent titles. However, it upheld the third sale insofar as Luis’s inchoate share and found respondents to be possessors and builders in good faith. The Court of Appeals (CA) reversed the RTC, dismissing the complaint, holding that respondents were innocent purchasers for value who relied on the face of TCT No. T-20,677.

ISSUE

Whether the Court of Appeals erred in ordering the dismissal of petitioners’ complaint.

RULING

The Petition lacks merit. The Supreme Court affirmed the CA’s decision. Preliminarily, the Petition raised factual questions not generally cognizable in a Rule 45 petition, and the RTC’s findings that petitioners failed to prove forgery or that the sales did not occur are binding. The documents in question are public documents enjoying a presumption of regularity.
On the core issue, the Court ruled that the second sale, executed in 1963, was governed by the Civil Code. Under Article 166 of the Civil Code, the husband could not alienate conjugal real property without the wife’s consent. However, Article 173 provided the wife a remedy: she may, during the marriage and within ten years from the transaction, ask the courts for its annulment. The Court adopted the view that a sale of conjugal property by the husband without the wife’s consent is not void but voidable, and the wife’s right to annul prescribes ten years from the date of the transaction.
In this case, the property was conjugal, acquired in 1963. The second sale was executed in 1963. Flora’s action to annul the sale prescribed in 1973. She filed her complaint only in 2008, long after the prescriptive period had lapsed. Consequently, she was barred from questioning the sale. Since the second sale could no longer be annulled, Luis became the sole registered owner under TCT No. T-20,677. Respondents, as purchasers in good faith who relied on this clean title, acquired valid title. Therefore, the CA correctly dismissed the complaint.