FACTS:

The case involved the prosecution of petitioner Efren Pana, his wife Melecia, and others for murder. The RTC acquitted Efren but found Melecia and another person guilty, imposing the death penalty. The RTC also ordered Melecia and the other person to pay civil indemnity, moral damages, and actual damages to the victims' heirs. On appeal, the Court modified the penalty to reclusion perpetua. The Court affirmed the awards of civil indemnity and moral damages but replaced the award for actual damages with temperate damages. Exemplary damages were also awarded per victim. The decision became final and executory. The RTC then issued a writ of execution, resulting in the levy of real properties registered in the names of Efren and Melecia.

Efren and Melecia filed a motion to quash the writ of execution, arguing that the levied properties were conjugal assets. The RTC denied the motion, prompting the spouses to file a petition for certiorari before the CA. The CA dismissed the petition, leading Efren to file the present petition for review on certiorari. The main issue in this case is whether or not the conjugal properties of Efren and Melecia can be levied and executed upon for the satisfaction of Melecia's civil liability in the murder case.

ISSUES:

1. • Whether the conjugal properties of spouses Efren and Melecia can be levied and executed upon for the satisfaction of Melecia's civil liability in the murder case.

RULING:

1. • The Supreme Court held that the conjugal properties of spouses Efren and Melecia cannot be levied and executed upon for the satisfaction of Melecia's civil liability in the murder case. The Court ruled that the property relation between the couple was governed by the conjugal partnership of gains under the Civil Code, and that the transitory provision of the Family Code did not automatically convert such conjugal partnerships of gains into absolute community of property relations unless there was a prenuptial agreement. Since Efren and Melecia did not have a prenuptial agreement, their conjugal partnership of gains remained in effect and could not be modified post-marriage.

PRINCIPLES:

• Conjugal properties cannot be levied and executed upon for the satisfaction of one spouse's civil liability arising from a criminal offense unless specifically provided by law.

• The property relation between spouses is determined by the law in force at the time of their marriage, unless they entered into a valid prenuptial agreement.

• Marriage settlements cannot be modified after the celebration of the marriage, except in specific circumstances such as legal separation and reconciliation of legally separated spouses.