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Heirs of Ignacia Aguilar-Reyes vs. Mijares

The Supreme Court ruled that a sale by Vicente Reyes of a property co-owned with his wife Ignacia Aguilar-Reyes to the Mijares spouses was voidable, not valid, overturning the Court of Appeals. The property was part of the conjugal estate of Vicente and Ignacia, purchased using funds from their business. Though separated since 1974, Ignacia did not consent to the 1983 sale. The Supreme Court reinstated the trial court's ruling annulling the sale and canceling the Mijares' title, as under the Civil Code, such a sale by the husband without the wife's consent is voidable.

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Salman Johayr
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356 views2 pages

Heirs of Ignacia Aguilar-Reyes vs. Mijares

The Supreme Court ruled that a sale by Vicente Reyes of a property co-owned with his wife Ignacia Aguilar-Reyes to the Mijares spouses was voidable, not valid, overturning the Court of Appeals. The property was part of the conjugal estate of Vicente and Ignacia, purchased using funds from their business. Though separated since 1974, Ignacia did not consent to the 1983 sale. The Supreme Court reinstated the trial court's ruling annulling the sale and canceling the Mijares' title, as under the Civil Code, such a sale by the husband without the wife's consent is voidable.

Uploaded by

Salman Johayr
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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Heirs of Ignacia Aguilar-Reyes vs.

Mijares

FACTS:
The controversy stemmed from a dispute over Lot No. 4349-B-2, registered in the name of
Spouses Vicente Reyes and Ignacia Aguilar-Reyes. Said lot and the apartments built thereon
were part of the spouses’ conjugal properties having been purchased using conjugal funds from
their garments business. Vicente and Ignacia were married in 1960, but had been separated de
facto since 1974. Sometime in1984, Ignacia learned that on March 1, 1983, Vicente sold Lot No.
4349-B-2 to respondent spouses Cipriano and Florentina Mijares. On August 9, 1984, Ignacia,
through her counsel, sent a letter to respondent spouses demanding the return of her share in the
lot. Pending the appeal, Ignacia died and she was substituted by her compulsory heirs. Spouses
Mijares claimed that they are buyers in good faith.

RTC RULING:
The RTC declared the sale void with respect to the share of Ignacia. The RTC later modified its
decision by declaring the sale void in its entirety and ordering Vicente Reyes to reimburse
Spouses Mijares the purchase price.

CA RULING:
The CA reversed and set aside the decision of the RTC. It ruled that notwithstanding the absence
of Ignacia’s consent to the sale, the same must be held valid in favor of Spouses Mijares because
they were innocent purchasers for value.

ISSUE:
Whether the sale is void, valid, or voidable

SC RULING:
The SC reversed and set aside the CA’s decision. The RTC’s decision which annulled the Deed
of Absolute Sale and ordered the Register of Deeds to cancel the title in the name of Spouses
Mijares is reinstated. The husband could not alienate or encumber any conjugal real property
without the consent, express or implied, of the wife otherwise, the contract is voidable. Indeed, in
several cases it has been ruled that such alienation or encumbrance by the husband is void. The
better view, however, is to consider the transaction as merely voidable and not void. This is
consistent with the provision of the Civil Code which the wife could, during the marriage and
within 10 years from the questioned transaction, seek its annulment.

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