Salas v. Aguila
REITERATIONFacts
The Antecedents: Petitioner Juan Sevilla Salas, Jr. (Salas) and respondent Eden Villena Aguila (Aguila) were married on September 7, 1985. They had a daughter, Joan Jiselle, born on June 7, 1986. Five months later, Salas left their conjugal dwelling and had no further communication with Aguila or their daughter. On October 7, 2003, Aguila filed a Petition for Declaration of Nullity of Marriage citing psychological incapacity under Article 36 of the Family Code, stating they had no conjugal properties. The RTC declared the marriage null and void. Subsequently, Aguila discovered properties registered in the name of "Juan S. Salas, married to Rubina C. Salas." She filed a Manifestation and Motion to partition these properties. Salas opposed, claiming the properties were already partitioned, citing alleged "Waived Properties" he transferred to Aguila. Rubina C. Salas intervened, claiming the discovered properties were her paraphernal properties and that she was not married to Salas. Procedural History: The RTC ordered the partition of the discovered properties, finding them to be conjugal and noting Salas' failure to prove the existence of the "Waived Properties." The RTC denied Salas' motion for reconsideration, emphasizing that the Transfer Certificates of Title (TCTs) indicated Salas as the registered owner. Rubina's intervention was also denied. The Court of Appeals (CA) affirmed the RTC's decision, holding that Aguila's initial statement was a palpable mistake, not a judicial admission, as she discovered the properties later. The CA also ruled that Rubina could not collaterally attack the TCTs. The Petition: Salas filed a petition for review on certiorari, assailing the CA's affirmation of the RTC's order to partition the discovered properties and its denial of Rubina's intervention.
Issue(s)
Whether the Court of Appeals erred in affirming the trial court’s decision ordering the partition of the parcels of land covered by TCT Nos. N-259299-A and N-255497 in Quezon City and TCT No. 243373 in Manila between petitioner and respondent. Whether the Court of Appeals erred in affirming the trial court’s decision in not allowing Rubina C. Cortez to intervene in this case.
Ruling
The petition is denied. The Decision dated March 16, 2012, and the Resolution dated June 28, 2012, of the Court of Appeals in CA-G.R. CV No. 95322 are affirmed. The discovered properties are to be partitioned between Salas and Aguila on the basis of co-ownership under Article 147 of the Family Code.
Ratio Decidendi
On the partition of properties: The Court affirmed the partition of the discovered properties. It held that Salas failed to prove the existence and acquisition of the "Waived Properties" during the marriage, as the submitted documents were mere photocopies and lacked the presumption of regularity. Conversely, the TCTs for the discovered properties were entered during the marriage of Salas and Aguila, creating a presumption that they were acquired through their joint efforts. The Court reiterated that factual findings of the RTC, affirmed by the CA, are binding. The Court clarified that while Aguila's initial statement about having no conjugal property was not a judicial admission due to palpable mistake, the properties acquired during the void marriage are governed by co-ownership under Article 147 of the Family Code, not the conjugal partnership of gains. This regime presumes that properties acquired during cohabitation are through joint efforts, owned in equal shares, and neither party can dispose of their share without the other's consent. On the intervention of Rubina C. Salas: The Court found the contention unmeritorious. The TCTs stated "Juan S. Salas, married to Rubina C. Salas" as the registered owner, but the phrase "married to" is merely descriptive of the civil status. Salas did not initially dispute the ownership, only supporting Rubina's claim after her intervention. Rubina failed to prove her title or legal interest in the discovered properties, thus lacking the legal standing to intervene as per the Rules of Court. The Court emphasized that a Torrens title is generally conclusive evidence of ownership, and Rubina could not collaterally attack the certificate of title. Furthermore, if the TCTs were indeed erroneous, Salas and Rubina were at fault for failing to correct them.
Main Doctrine
Properties acquired during a union of parties who are capacitated to marry but whose marriage is declared void under Article 36 of the Family Code are governed by the rules on co-ownership under Article 147 of the Family Code, not the regime of conjugal partnership of gains, unless proven otherwise.