Patrocinia Ravina v. Mary Ann · G.R. 160708

Petitioner: Patrocinia Ravina
Respondent: Mary Ann P. Villa Abrille
Citation: G.R. No. 160708
Court: Supreme Court
Division: Second Division
Decided: October 16, 2009

Summary

This Supreme Court case involves the validity of a sale of conjugal property without the wife's consent. Pedro Villa Abrille sold the family's conjugal house and lot (TCT No. T-88674) to the Ravina spouses without his wife Mary Ann's consent or signature in 1991. The property was acquired during marriage in 1982 and presumed conjugal under Article 160 of the Civil Code. The Supreme Court affirmed the Court of Appeals' ruling that under Article 124 of the Family Code, the sale was null and void as it lacked the required consent of both spouses. The Court rejected petitioners' claim of being buyers in good faith since they were aware of Mary Ann's objection but proceeded anyway. The decision reinforces the protection of conjugal property rights and the requirement of both spouses' consent for valid disposition of marital assets.

Statutes applied

Civil Code, Art. 449

Related cases

Other Philippine cases on the same provisions and issues.

Ernesto Basquiñez Saniano v. Joselina Basquiñez Sañano G.R. No. 261733
Francisco S. Dizon v. Sebastian Gonzaga G.R. No. 138863
Pen Development Corporation v. Martinez Leyba G.R. No. 211845
Spouses Crispin Aquino v. Aquino G.R. No. 182754
Bank of the Philippine Islands v. Vicente Victor C. Sanchez G.R. No. 179518
Government Service Insurance System (Gsis) v. The Province of Tarlac G.R. No. 157860
Emilio Bugatti v. Court of Appeals G.R. No. 138113
Frederic de Backer v. Juana F. Shermer Joined By Her Husband Raymond Shermer G.R. No. 243834

By the Intellegal Editorial Board · October 16, 2009

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