Virgilio Maquilan v. Dita Maquilan

Summary

Spouses Virgilio and Dita Maquilan entered into a compromise agreement dividing their conjugal properties during a pending nullity of marriage case, after Dita was convicted of adultery. Virgilio later sought to repudiate the agreement, arguing that his wife's adultery conviction disqualified her from sharing conjugal property and that he received inadequate legal advice. The Supreme Court upheld the validity of the compromise agreement, ruling that adultery conviction under prision correccional does not carry civil interdiction and does not disqualify a spouse from property division. The Court emphasized that voluntary property separation with judicial approval is permitted under the Family Code, even during pending nullity proceedings, provided creditors' rights are protected. The decision clarifies that criminal conviction for adultery does not automatically result in forfeiture of conjugal property rights.