G.R. No. 48403; October 28, 1942
AGUSTIN DE LUNA, ET AL., petitioners-appellants, vs. JOSE LINATOC, respondent-appellee.

FACTS

The petitioners (Agustin de Luna et al.) sought the annulment of sales of real property executed by the wife (one of the petitioners) in favor of the respondent, Jose Linatoc. The Court of Appeals found that no deceit had been committed by the appellee upon the appellants. This conclusion was drawn from facts that were either undisputed or clearly established by the evidence. Subsequently, the husband executed a document (Exhibit I) referring to the sales, stating that his wife sold the lands with his knowledge and consent. The case involves issues regarding the authority of the wife to sell conjugal property and the validity of a partition made between the spouses during marriage.

ISSUE

1. Whether the Supreme Court can review the factual conclusion of the Court of Appeals that no deceit was committed.
2. Whether the document (Exhibit I) executed by the husband constitutes a confirmation, ratification, or recognition of the sales.
3. Whether the wife had authority to sell the property, considering an attempted partition of conjugal assets during marriage.
4. Whether mistake of law renders the contracts voidable.
5. Whether petitioners can repudiate the sales based on their own illegal act of partitioning conjugal property.
6. How the contracts of sale should be interpreted under Article 1284 of the Civil Code.

RULING

1. On review of factual conclusions: The Supreme Court held that it cannot examine the conclusion of the Court of Appeals on the existence of deceit. The Court’s inquiry into factual deductions is limited to cases where the inference is manifestly mistaken, absurd, or impossible. Since fair-minded men may differ on whether fraud existed, the Supreme Court declined to disturb the appellate court’s discretion.
2. On Exhibit I: The document is neither a confirmation nor a ratification but a “reconocimiento” or recognition. Confirmation cures a vice of nullity, and ratification grants authority to an unauthorized agent. Recognition merely cures a defect of proof. Here, the husband stated his wife acted with his knowledge and consent, thus complying with the statute of frauds regarding written authority for the sale of real property. The wife was acting as his authorized agent.
3. On authority of the wife and partition: As an agent, the wife could sell the property, but the partition attempted during marriage was illegal and void under Article 1432 of the Civil Code, as there was no judicial order for separation of property. Thus, the property remained conjugal partnership assets. However, under Article 1614 of the Civil Code, the wife may bind the conjugal partnership with the husband’s consent, which was given in Exhibit I.
4. On mistake of law: Mistake of law does not make a contract voidable, as ignorance of the law excuses no one from compliance (Article 2, Civil Code). The petitioners’ lack of knowledge of the prohibition against partition during marriage is not a valid ground for annulment.
5. On taking advantage of one’s wrong: Petitioners cannot repudiate the sales by relying on their own unlawful act of partitioning conjugal property, which violates public policy under Article 1432 designed to protect creditors and third parties. The legal maxim that no one can profit from their own wrong applies.
6. On interpretation of contracts: The contracts (Exhibits C, D, and I) admit two interpretations: one invalid (referring to separate property from the partition) and one valid (referring to conjugal property). Under Article 1284 of the Civil Code, the interpretation that makes the contracts effective and legal is adopted. Thus, the deeds are binding as transactions involving conjugal partnership property.
Petition denied.