Manuel O. Fuentes v. Conrado G. Roca

Summary

The Supreme Court ruled that a husband's sale of conjugal real property without his wife's genuine written consent is void under the Family Code. Tarciano Roca sold conjugal land to the Fuentes spouses using a forged affidavit of consent from his estranged wife Rosario. The Court found the signature was forged based on significant variance with specimen signatures and the notary's falsified jurat. Applying Family Code Article 124, the sale was declared void from the beginning, making the action to declare nullity imprescriptible under Civil Code Article 1410. The Fuentes spouses, as good faith possessors, were entitled to reimbursement of the purchase price and compensation for improvements introduced on the property. This case establishes important precedent on spousal consent requirements and the distinction between void and voidable sales of conjugal property under the Family Code.