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PATROCINIA RAVINA v. MARY ANN P. VILLA ABRILLE

FACTS:

The case involves a dispute between spouses Pedro Villa Abrille and Mary Ann Pasaol Villa Abrille over a parcel of land and a house in Davao City. The spouses acquired Lot 7 in 1982 and built a house on it with the proceeds of a loan. Pedro owned an adjacent lot, Lot 8, which he acquired before their marriage. In 1991, Pedro had an extramarital affair and offered to sell the house and both lots to the Ravinas without Mary Ann's consent. Mary Ann objected, but Pedro sold the property anyway. On July 5, 1991, Pedro forcibly removed the movables from the house and prevented Mary Ann and their children from entering. Mary Ann and the children filed a complaint seeking annulment of the sale, damages, and injunction. The RTC ruled in favor of Mary Ann, declaring the sale of Lot 8 void and the sale of the house and Lot 7 void as to Mary Ann's share. The RTC awarded damages to Mary Ann and the children. The Court of Appeals modified the decision, declaring the sale of Lot 8 valid but declaring the sale of the house and Lot 7 null and void. The Court of Appeals ordered Pedro to return the consideration for the sale of Lot 7 and the house to the Ravinas and ordered the Ravinas to reconvey the property to Pedro and Mary Ann. The Court of Appeals affirmed the damages awarded by the RTC. Petitioners filed a motion for reconsideration, which was denied. They then filed a petition for review before the Supreme Court to challenge the Court of Appeals' ruling.

ISSUES:

  1. Whether the lot covered by TCT No. T-88674 is an exclusive property of Pedro or conjugal property.

  2. Whether the sale of the said lot by Pedro was valid considering the absence of Mary Ann's consent.

  3. Whether the petitioners, as buyers in good faith, are liable for damages.

  4. Whether the petitioners can be considered buyers for value in good faith

  5. Whether the petitioners are entitled to reimbursement for improvements made to the property

  6. Whether the damages awarded to the respondents are supported by the evidence

RULING:

  1. The lot covered by TCT No. T-88674 is conjugal property. The presumption under Article 160 of the New Civil Code is that all property of the marriage is presumed to belong to the conjugal partnership, unless it is proven to belong exclusively to one spouse. Since there was no evidence to prove that the subject property was exclusively owned by Pedro, the presumption of conjugal nature of the property stands.

  2. The sale of the lot covered by TCT No. T-88674 by Pedro without the consent of Mary Ann is void. Article 124 of the Family Code explicitly states that the disposition or encumbrance of conjugal property without the consent of both spouses is void. Moreover, the sale was executed after the effectivity of the Family Code, which governs such transactions.

  3. The petitioners, as buyers in good faith, are still liable for damages. Being buyers in good faith means they bought the property without notice of any claim or interest by another person. However, their claim of being buyers in good faith does not exempt them from the requirement of obtaining the consent of both spouses for the sale of conjugal property. Therefore, their reliance on the certificates of title and payment of a full and fair price does not absolve them from liability.

  4. The petitioners cannot be considered buyers for value in good faith because they failed to obtain the written consent of the wife who had an interest in the property. They were aware of the wife's objection to the sale, yet they proceeded with the purchase without her consent. Therefore, they cannot invoke the protection accorded to purchasers in good faith.

  5. The petitioners are not entitled to reimbursement for improvements made to the property after their good faith had ceased. Article 449 of the New Civil Code applies, which states that one who builds, plants, or sows in bad faith on the land of another loses what has been built, planted, or sown without the right to indemnity.

  6. The damages awarded to the respondents are supported by the evidence. The manner in which the respondents were removed from their family home was condemnable. The petitioners acted contrary to the norms of justice, honesty, and good faith. Therefore, they must be held responsible for the damages caused.

PRINCIPLES:

  • All property of the marriage is presumed to belong to the conjugal partnership, unless proven to belong exclusively to one spouse. (Article 160, New Civil Code)

  • Disposition or encumbrance of conjugal property without the consent of both spouses is void. (Article 124, Family Code)

  • A purchaser in good faith is one who buys the property of another without notice of any claim or interest by another person and pays a full and fair price for the same. However, being a buyer in good faith does not exempt the buyer from complying with legal requirements, such as obtaining the consent of both spouses in the sale of conjugal property.

  • A buyer for value in good faith must show that they relied on the face of the seller's certificate of title, except in cases where the seller's capacity to sell is restricted.

  • The restoration of what has been given is proper when a voidable contract is annulled.

  • The relationship between the parties in any contract, even if subsequently annulled, must be characterized by good faith and fair dealing.

  • The principle of non-enrichment at another's expense requires that justice and equity be observed.

  • Every person must, in the exercise of their rights and the performance of their duties, act with justice, give everyone their due, and observe honesty and good faith.

  • Any person who willfully causes loss or injury to another in a manner contrary to morals, good customs, or public policy shall compensate the latter for the damages caused.