Ravina vs. Villa Abrille

Under Article 124 of the Family Code, the disposition or encumbrance of conjugal partnership property by one spouse without the written consent of the other or the authority of the court is void, and a third-party buyer who proceeds with the purchase despite knowing of the seller's marriage and the non-consenting spouse's objection cannot be considered a purchaser in good faith.

Pedro Villa Abrille, who had become estranged from his family due to an illicit affair, attempted to sell the family home and two parcels of land—one exclusively owned by him and another acquired during his marriage to Mary Ann Villa Abrille—to Spouses Ravina. Mary Ann explicitly objected to the sale, but Pedro proceeded to execute the deed without her consent and subsequently, with the help of the buyers and armed men, forcibly evicted Mary Ann and their children from the premises.

• Respondents Mary Ann and Pedro Villa Abrille are spouses who acquired Lot 7 (TCT No. T-88674) in 1982 during their marriage.
• Pedro also owned an adjacent lot, Lot 8 (TCT No. T-26471), which he acquired before the marriage and registered solely in his name.
• Through joint efforts and a loan from DBP, the spouses built a house that stood on both Lot 7 and Lot 8.
• In 1991, Pedro began an affair, neglected his family, and offered to sell the house and both lots to Petitioners Patrocinia and Wilfredo Ravina.
• Mary Ann objected to the sale and notified the Petitioners of her objection, but Pedro proceeded to sell the house and both lots via a Deed of Sale dated June 21, 1991, which Mary Ann did not sign.
• On July 5, 1991, while Mary Ann was out and the children were at school, Pedro, in connivance with the Petitioners and accompanied by armed CAFGU members, forcibly transferred the family's belongings to an apartment and barred them from re-entering the home.
• Mary Ann and her children filed a complaint for Annulment of Sale, Specific Performance, Damages, and Attorney’s Fees.
• The RTC ruled the sale valid for Pedro's exclusive lot and his half-share of the conjugal lot, but void for Mary Ann's share; the CA modified this, declaring the sale of the conjugal lot and house entirely void.

• The subject Lot 7 covered by TCT No. T-88674 was the exclusive property of Pedro, allegedly acquired through barter/exchange using proceeds from the sale of his other exclusive properties.
• They are innocent purchasers for value (buyers in good faith) who relied on the face of the certificates of title.
• They should not be held liable for damages as the award is not supported by evidence.

• The property (Lot 7) and the house were acquired during the marriage and are conjugal in nature.
• The sale was made without Mary Ann's consent and despite her known objection.
• The forcible eviction caused stress, tension, and anxiety to the family, justifying the claim for damages.

• Procedural Issues:
  • N/A
• Substantive Issues:
  • Whether Lot 7 covered by TCT No. T-88674 is the exclusive property of Pedro or belongs to the conjugal partnership.
  • Whether the sale of Lot 7 and the house by Pedro to the Petitioners is valid despite the lack of Mary Ann's consent.
  • Whether the Petitioners are purchasers in good faith.
  • Whether the Petitioners are entitled to reimbursement for improvements made on the property.

• Procedural:
  • N/A
• Substantive:
  • The Court ruled that Lot 7 is conjugal property because it was acquired in 1982 during the marriage, and Petitioners failed to present clear and convincing evidence to rebut the presumption under Article 160 of the Civil Code that property acquired during marriage is conjugal.
  • The Court declared the sale of Lot 7 and the house void under Article 124 of the Family Code (the governing law at the time of the 1991 sale), which mandates that any disposition of conjugal property without the written consent of the other spouse is void, not merely voidable.
  • The Court held that Petitioners were not buyers in good faith because they knew Pedro was married, Mary Ann's signature was missing from the deed, and they had been explicitly notified by Mary Ann's lawyer of her objection prior to the sale.
  • The Court ruled that Petitioners are builders in bad faith under Article 449 of the Civil Code and thus lose any improvements made on the property without right to indemnity, as they introduced renovations after the complaint was filed and their good faith had ceased.

• Article 124, Family Code — Provides that the administration of conjugal property belongs to both spouses jointly, and any disposition or encumbrance by one spouse without the court's authority or the other spouse's written consent is void. In this case, this doctrine rendered the sale of the conjugal lot and house null and void.
• Presumption of Conjugal Partnership (Art. 160, Civil Code) — All property of the marriage is presumed to belong to the conjugal partnership unless proven to pertain exclusively to the husband or wife. This presumption was applied to classify Lot 7 as conjugal property absent proof of exclusive ownership by the husband.
• Buyer in Good Faith — A buyer who purchases property without notice that another person has a right to or interest in it; however, a buyer dealing with a seller with restricted capacity (like a married person) must inquire into the capacity to sell. This principle was used to deny the Petitioners' claim of good faith as they failed to secure the wife's consent despite knowledge of the marriage.
• Builder in Bad Faith (Art. 449, Civil Code) — He who builds, plants, or sows in bad faith on the land of another loses what is built, planted, or sown without right to indemnity. This was applied to deny Petitioners reimbursement for renovations made during the pendency of the case.
• Abuse of Rights (Art. 19 & 21, Civil Code) — Requires every person to act with justice, give everyone his due, and observe honesty and good faith; willful injury contrary to morals requires compensation. This doctrine justified the award of damages for the surreptitious and forcible eviction of the respondents.

• "In the absence of such authority or consent, the disposition or encumbrance shall be void."
• "The relationship between the parties in any contract even if subsequently annulled must always be characterized and punctuated by good faith and fair dealing."
• "The manner by which respondent and her children were removed from the family home deserves our condemnation."

• Castro v. Miat — Cited to support the application of the presumption that property acquired during marriage is conjugal.
• San Lorenzo Development Corporation v. Court of Appeals — Cited to define a purchaser in good faith.
• Bautista v. Silva — Cited to establish that a buyer dealing with land registered in the name of a seller whose capacity is restricted (e.g., by marriage laws) must inquire into the seller's capacity to establish good faith.
• Heirs of Ignacia Aguilar-Reyes v. Mijares — Cited regarding the principle of restoring what has been given when a voidable contract is annulled, based on equity.
• Lumungo v. Usman — Cited to support the ruling that a builder in bad faith loses improvements without indemnity under Article 449.

• Article 160, New Civil Code — Establishes the presumption that all property of the marriage belongs to the conjugal partnership.
• Article 124, Family Code — Governs the disposition of conjugal property, declaring sales without spousal consent as void; applied as the governing law for the 1991 transaction.
• Article 449, New Civil Code — States that a builder in bad faith loses what is built without indemnity; applied to the improvements made by Petitioners.
• Article 19, Civil Code — General principle of law requiring justice, honesty, and good faith in the exercise of rights.
• Article 21, Civil Code — Mandates compensation for damages caused by acts contrary to morals, good customs, or public policy.