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Case Digest - G.R. No. L-31618 - Mendoza vs. Reyes

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0% found this document useful (0 votes)
48 views2 pages

Case Digest - G.R. No. L-31618 - Mendoza vs. Reyes

Uploaded by

Jeriel Ivan
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Title

Mendoza vs. Reyes

Case Decision Date


G.R. No. L-31618 Aug 17, 1983

A husband files a complaint to annul a deed of sale of conjugal properties,


claiming his wife sold them without his knowledge, and the court rules in his
favor, declaring the sale null and void and ordering the cancellation of the
transfer certificates of title.

Case Digest (G.R. No. L-31618)


Comprehensive
Facts:
The case "Mendoza v. Reyes" revolves around a dispute concerning the sale of conjugal
properties. The petitioners, Efren V. Mendoza and Inocencia R. De Mendoza, purchased
two parcels of land with improvements from Julia R. De Reyes. The respondent,
Ponciano S. Reyes, filed a complaint to annul the deed of sale, asserting that the
properties were conjugal and that his wife sold them without his knowledge or consent.
The properties in question were located at Retiro Street, Quezon City, and were acquired
during the marriage of Ponciano and Julia Reyes. The funds used to purchase the
properties and construct improvements were sourced from loans obtained jointly by the
spouses from the Rehabilitation Finance Corporation (RFC). Initially, the Court of First
Instance of Rizal ruled in favor of Julia R. De Reyes, declaring the properties as her
exclusive paraphernal properties. However, the Court of Appeals reversed this decision,
declaring the sale null and void concerning Ponciano's one-half share and ordering the
cancellation of the transfer certificates of title. The case was subsequently brought to the
Supreme Court for review.

Issue:
1. Are the properties in question conjugal or paraphernal?
2. Are the petitioners, Efren V. Mendoza and Inocencia R. De Mendoza, buyers in good
faith?
3. Does the principle of estoppel apply to prevent Ponciano S. Reyes from claiming the
properties as conjugal?
4. Would the annulment of the deed of sale result in unjust enrichment for Ponciano S.
Reyes?
Ruling:
1. The properties in question are conjugal.
2. The petitioners, Efren V. Mendoza and Inocencia R. De Mendoza, are not buyers in
good faith.
3. The principle of estoppel does not apply in this case.
4. The annulment of the deed of sale does not result in unjust enrichment for Ponciano
S. Reyes.

Ratio:

1. The Supreme Court upheld the presumption under Article 160 of the Civil Code that
properties acquired during the marriage are conjugal unless proven otherwise. The
properties were acquired through loans obtained jointly by the spouses from the
RFC, making them conjugal in nature. The testimony of Julia R. De Reyes claiming
the properties as paraphernal was unsupported by evidence and contradicted by the
mortgage contracts and other documents showing the properties were paid for with
conjugal funds.

2. The Court determined that the petitioners were not buyers in good faith. The
properties were registered in the name of Julia Reyes "married to Ponciano Reyes,"
and the mortgage contracts were duly annotated on the transfer certificates of title.
The petitioners were charged with notice of the conjugal nature of the properties
and the existence of the mortgages. Additionally, the petitioners required Ponciano's
consent for the lease of the properties but did not seek his consent for the sale,
indicating a lack of good faith.

3. The principle of estoppel was not applicable because there was no evidence that
Ponciano S. Reyes intentionally and deliberately misled the petitioners into believing
the properties were paraphernal. The alleged misrepresentation was not addressed
to the petitioners, and they did not rely on it when purchasing the properties.

4. The annulment of the deed of sale does not result in unjust enrichment for Ponciano
S. Reyes. The benefit from the sale accrued to Julia R. De Reyes, not Ponciano. Since
Ponciano did not receive any part of the proceeds and his wife aligned herself with
the petitioners, there was no unjust enrichment.

The Supreme Court affirmed the decision of the Court of Appeals, denying the petitions
for review on certiorari for lack of merit.

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