David v. Pelayo

Summary

This case involves the validity of a deed of absolute sale of agricultural land executed between spouses David and Lorenza Pelayo and Melki Perez. The Supreme Court upheld the validity of the sale despite the wife's incomplete signature, finding implied marital consent through her participation as witness with knowledge of the transaction. The Court applied the law of the case doctrine regarding a prior ruling that the deed was not invalidated by RA 6657's registration requirements. Key legal principles established include: (1) marital consent for conjugal property disposition may be implied from circumstances; (2) lack of marital consent makes contracts voidable, not void ab initio; (3) failure to seek annulment within the prescribed period validates the transaction; and (4) agents may purchase principal's property with consent. The decision affirmed that adequate consideration existed through services rendered plus monetary payment, rejecting claims of simulation or fraud.