Spouses Antonio v. Court of Appeals

Summary

This Supreme Court case involved spouses Gilda and Judie Corpuz who owned conjugal property in Koronadal, South Cotabato. While Gilda was in Manila seeking overseas employment, her husband Judie sold their remaining half portion of their residential property to the Guiang spouses without her knowledge or consent through a Deed of Transfer of Rights dated March 1, 1990. Upon Gilda's return, she discovered the unauthorized sale and filed suit to declare it null and void. The Supreme Court affirmed the lower courts' decisions, establishing the important principle that under Article 124 of the Family Code, any disposition or encumbrance of conjugal property without both spouses' consent is null and void, not merely voidable as under the previous Civil Code provisions. The Court distinguished between contracts where consent is vitiated (merely voidable) versus contracts where consent is totally absent (void). The attempted ratification through an amicable settlement was also declared void, as void contracts cannot be ratified under Article 1409 of the Civil Code. This case clarifies the stricter requirements for conjugal property transactions under the Family Code compared to the Civil Code.