Abalos v. Macatangay, Jr.

Summary

The Supreme Court reversed the Court of Appeals decision ordering specific performance of a property sale involving conjugal property. Spouses Abalos owned a Makati property which the husband attempted to sell through a Receipt and Memorandum of Agreement, while the wife later executed a separate Contract to Sell through her attorney-in-fact. The Court ruled that the RMOA was merely an option contract without valid consideration, not a perfected sale. Even if considered a sale, it would be void for violating Article 166 of the Civil Code requiring both spouses' consent for conjugal property alienation. The separate documents with divergent terms could not create a valid transaction. The Court emphasized that conjugal property rights are inchoate until partnership liquidation, and void contracts cannot be ratified by subsequent acts. The complaint for specific performance was dismissed.