Barrido v. Nonato
REITERATIONFacts
The Antecedents: Respondent Leonardo V. Nonato and petitioner Marietta N. Barrido acquired a property consisting of a house and lot during their marriage. Their marriage was subsequently declared void on March 15, 1996, on the ground of psychological incapacity. Procedural History: Nonato sought partition of the property, but Barrido refused. Nonato filed a complaint for partition before the Municipal Trial Court in Cities (MTCC). The MTCC adjudicated the property to Barrido, awarding damages and attorney's fees to her. Nonato appealed to the Regional Trial Court (RTC), which reversed the MTCC decision, ordering the equitable partition of the property and reimbursement to their children for advances made. The Court of Appeals (CA) affirmed the RTC decision, holding that the MTCC had jurisdiction and that while Article 129 of the Family Code was misapplied, the dispositive portion correctly ordered partition. The Petition: Barrido filed a Petition for Review with the Supreme Court, questioning the CA's rulings on jurisdiction, the nature of the property as conjugal, and the applicability of Article 129 of the Family Code.
Issue(s)
Whether the MTCC had jurisdiction over the partition case. Whether the subject property remained conjugal despite Barrido's claim of sale to their children. Whether Article 129 of the Family Code was applicable.
Ruling
The petition is denied. The Decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the MTCC's Jurisdiction: The Court held that the MTCC had jurisdiction over the case. Real actions, including partition, fall within the exclusive original jurisdiction of Metropolitan Trial Courts, Municipal Trial Courts, and Municipal Circuit Trial Courts if the assessed value of the property or interest therein does not exceed ₱20,000.00 (or ₱50,000.00 in Metro Manila), exclusive of interest, damages, attorney's fees, and costs. In this case, the subject property's assessed value was ₱8,080.00, which clearly falls within the MTCC's jurisdictional limit as provided by Section 33(3) of Batas Pambansa Bilang 129, as amended by Republic Act No. 7691. Therefore, the MTCC correctly took cognizance of the case. On the Nature of the Property and Barrido's Claim of Sale: The Court ruled that the subject property remained owned in common by Nonato and Barrido. Their marriage was declared void under Article 36 of the Family Code due to psychological incapacity. Consequently, their property relations are governed by Article 147 of the Family Code, which treats their union as a co-ownership. Properties acquired during the union are presumed to have been obtained through their joint efforts and are owned in equal shares. Barrido's claim that the property was sold to their children was unsubstantiated. The alleged Deed of Sale was a private document, not notarized, and was merely annexed to her position paper without proof of its due execution and authenticity, rendering it inadmissible in evidence. The title to the property also remained in the names of the former spouses. On the Applicability of Article 129 vs. Article 147 of the Family Code: The Court clarified that while Article 129 of the Family Code provides for the procedure in case of dissolution of the conjugal partnership regime, Article 147 specifically governs the effects of void marriages on the spouses' property relations. Article 147 applies when a man and a woman, capacitated to marry, live exclusively with each other as husband and wife under a void marriage. In such cases, their wages and salaries are owned in equal shares, and property acquired through their work or industry is governed by the rules on co-ownership. The Court cited Valdes v. Regional Trial Court, Branch 102, Quezon City and Mercado-Fehr v. Fehr to support the application of Article 147 in situations of void marriages due to psychological incapacity. The rules for conjugal partnership liquidation are irrelevant to the co-ownership that exists between spouses of void marriages.
Main Doctrine
In cases of void marriages due to psychological incapacity, the property relations of the parties are governed by Article 147 of the Family Code, which establishes a co-ownership over properties acquired through their joint efforts, work, or industry, with a presumption of joint acquisition in equal shares. A private document, such as an unnotarized Deed of Sale, is inadmissible as evidence unless its due execution and authenticity are proven.