Bienvenido v. Court of Appeals
REITERATIONFacts
The Antecedents: Aurelio P. Camacho contracted a second marriage with respondent Luisita C. Camacho in 1962, despite being validly married to Consejo Velasco since 1942. Aurelio and Luisita lived together and begot a child. Aurelio later met petitioner Nenita T. Bienvenido in 1967 and lived with her from 1968 until his death in 1988. Aurelio purchased a house and lot in Quezon City in 1982, with the title issued in his name, described as single. In 1984, Aurelio sold this property to Nenita for P250,000.00, and a new title was issued in Nenita's name in 1985. Luisita claimed to have learned of Nenita's presence in the property and her claim as owner in 1988. Procedural History: Respondent Luisita and her son Chito filed a complaint seeking the annulment of the sale to Nenita, alleging forgery and fraud. The Regional Trial Court (RTC) ruled in favor of Nenita, upholding the sale and dismissing the complaint, finding the deed of sale genuine and the respondents in estoppel. The Court of Appeals (CA) reversed the RTC decision, annulling the sale and declaring Luisita and Aurelio as owners, holding that the property belonged to their conjugal partnership and the sale to Nenita was void. The CA presumed the validity of Aurelio's marriage to Luisita, stating that petitioner failed to prove otherwise. The CA also applied Article 739 of the Civil Code to declare the sale void. The Petition: Petitioner Nenita Bienvenido sought review of the CA decision, arguing that the CA erred in presuming the validity of Aurelio's marriage to Luisita, in applying Article 739 of the Civil Code, in ruling that the property was part of the conjugal partnership, and in not finding her to be a purchaser in good faith.
Issue(s)
Whether the marriage between Aurelio P. Camacho and respondent Luisita C. Camacho was valid. Whether the property in dispute belonged to the conjugal partnership of Aurelio and Luisita. Whether the sale of the property by Aurelio to petitioner Nenita T. Bienvenido was valid. Whether petitioner Nenita T. Bienvenido was a purchaser in good faith.
Ruling
The Supreme Court reversed the decision of the Court of Appeals, dismissed the complaint against petitioner Nenita T. Bienvenido, and declared the deed of sale in her favor and the corresponding Transfer Certificate of Title No. 326681 to be VALID. The Court held that Aurelio's marriage to Luisita was void for being bigamous, as his prior marriage to Consejo Velasco was subsisting and no exceptions under Article 83 of the Civil Code were proven. Consequently, the property could not be part of a conjugal partnership between Aurelio and Luisita. The Court further held that the sale to Nenita was valid, as she was a purchaser in good faith, and the CA erred in applying Article 739 of the Civil Code.
Ratio Decidendi
On the validity of the marriage between Aurelio and Luisita: The Court held that the marriage between Aurelio P. Camacho and respondent Luisita C. Camacho was void from its performance because Aurelio had a prior valid marriage to Consejo Velasco which was still subsisting at the time of his second marriage. The burden of proof to establish any of the exceptions under Article 83 of the Civil Code, such as the absence of the first spouse for seven years without news, rested on the respondents. Since respondents failed to discharge this burden, the presumption of validity of the second marriage was successfully assailed. The Court emphasized that the general rule is that any marriage contracted during the lifetime of the first spouse is illegal and void, unless specific exceptions are proven. On whether the property belonged to the conjugal partnership: As a consequence of the void marriage between Aurelio and Luisita, the Court ruled that there was no conjugal partnership between them. Therefore, the property in dispute could not have been part of any conjugal partnership. The property was acquired by Aurelio during his cohabitation with petitioner Nenita, and the deed of sale and title were issued in his name, described as single. The Court found no basis for the CA's conclusion that the property belonged to the conjugal partnership of Aurelio and Luisita. On the validity of the sale to Nenita: The Court found the sale of the property by Aurelio to petitioner Nenita to be valid. It held that the Court of Appeals erred in annulling the title at the instance of Luisita, whose marriage to Aurelio was void. The Court also clarified that Article 739 of the Civil Code, which declares donations void between persons guilty of adultery or concubinage, was misapplied. Firstly, an action for nullity of such donations can only be brought by the innocent spouse, which Luisita was not, given her void marriage. Secondly, the sale to Nenita was presumed valid until shown otherwise, supported by a deed of absolute sale and a Transfer Certificate of Title in her name. On whether Nenita was a purchaser in good faith: The Court ruled that Nenita was a purchaser in good faith. While she knew Aurelio's son, Chito, and that Aurelio had been living with her for twenty years, there was no evidence that she knew Aurelio was married to Luisita. Aurelio represented himself as single when he purchased the property and when he sold it to Nenita. Therefore, Nenita had no basis to know that Aurelio was married to Luisita, and her claim of good faith was upheld. The CA's ruling that Nenita ought to have known of Aurelio's marriage to Luisita was found to be without basis.
Main Doctrine
A subsequent marriage contracted during the subsistence of a prior valid marriage is void from its performance, unless the exceptions provided under Article 83 of the Civil Code are met. The burden of proof to establish these exceptions rests upon the party invoking them. Consequently, a sale of property by an individual who is presumed to be single, but who is in fact still married to a prior spouse, to a buyer who is unaware of the subsisting prior marriage, is valid if the buyer is in good faith and the property was acquired during the cohabitation with the buyer.