- Petitioner
- Maria B. Ching
- Respondent
- Joseph C. Goyanko, Jr.
- Citation
- G.R. No. 165879
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Carpio Morales, J.
- Decided
- November 10, 2006
Summary
The Supreme Court upheld the nullification of a property sale between Joseph Goyanko Sr. and his common-law wife Maria Ching. Despite the Regional Trial Court's finding that the sale was valid and that Ching was the actual owner who provided the purchase price, the Court of Appeals and Supreme Court declared the conveyance void under Civil Code Articles 1352, 1409, and 1490. The Court ruled that sales between common-law spouses are prohibited as contrary to public policy and morals, undermining family stability. The prohibition against property transfers between legitimate spouses extends to common-law relationships to prevent those in illicit unions from having better conditions than those in legal marriages. The Court rejected arguments of implied trust and allowed the change of legal theory from forgery to public policy violation, emphasizing that such conveyances are illegal per se regardless of the parties' intentions or financial arrangements.