Lily Elizabeth Bravo-Guerrero v. Edward P. Bravo

Summary

This Supreme Court case involves a family property dispute over two parcels of conjugal land in Makati City owned by spouses Mauricio and Simona Bravo. In 1970, Mauricio sold the properties to three of his grandchildren through a deed of sale for P1,000 plus assumption of mortgage debts totaling P15,000, based on a general power of attorney executed by Simona in 1966. After both spouses died, other grandchildren filed for judicial partition, claiming the sale was void for lack of Simona's consent and was merely simulated due to inadequate consideration. The Supreme Court upheld the validity of the sale, ruling that Simona's general power of attorney contained specific authorization for the sale, that only the wife could challenge such sales during marriage and within ten years, and that the consideration was not grossly inadequate. However, the Court granted a modified partition recognizing the co-ownership rights of all Roland Bravo's children in his share of the purchased properties. The decision clarifies important principles regarding conjugal property sales, powers of attorney, and the distinction between simulated contracts and inadequate consideration.