Melecio Domingo v. Spouses Genaro Molina

Summary

Melecio Domingo challenged the validity of his father Anastacio's 1978 sale of conjugal property to spouses Molina, arguing it was invalid without his deceased mother Flora's consent and was attended by fraud. The Supreme Court denied the petition, ruling that upon Flora's death in 1968, the conjugal partnership was dissolved and an implied co-ownership was created among the heirs. Under Article 493 of the Civil Code, Anastacio had the right to sell his undivided interest in the property as a co-owner. The spouses Molina became co-owners to the extent of Anastacio's interest. The Court found no fraud in the transaction and upheld the lower courts' factual findings. The decision clarifies the rights of surviving spouses over conjugal properties and the effects of property sales by co-owners without consent of other co-owners.