Union Bank of the Philippines v. Sps. Alfredo Ong

Summary

Union Bank sought to rescind a property sale between the Ong spouses and Jackson Lee, claiming it was made in fraud of creditors under Article 1381 of the Civil Code. The spouses had guaranteed BMC's P40 million credit facility and sold their Greenhills property for P12.5 million shortly before BMC filed for rehabilitation. The trial court found badges of fraud and nullified the sale, but the Court of Appeals reversed, finding insufficient evidence that the spouses lacked other assets. The Supreme Court affirmed, ruling that the sale had valid consideration supported by payment receipts, the purchase price was fair per expert testimony, and Union Bank failed to prove fraudulent intent or that the spouses had no other leviable property. The Court emphasized that rescission under Article 1381 requires proof that creditors cannot recover through other means, which was not established.