The Heirs of Lucio Acosta v. Spouses Aniceto Macatangay

Summary

The heirs of Lucio Acosta challenged the validity of property sales made by their predecessor 60+ years earlier, seeking reconveyance of Lot No. 988 and its subdivisions in Batangas. They claimed sales to Higino Cusi (1938) and Francisco Macatangay (1945) were void, arguing buyers were not in good faith and sales lacked spousal consent. The Supreme Court denied their petition, affirming lower courts' findings that respondents were buyers in good faith. The Court held that fraud was not proven by clear and convincing evidence, the 1938 sale preceded Lucio's marriage so spousal consent was unnecessary, and under Spanish Civil Code Article 1413, husbands could alienate conjugal property without wives' consent. The Court emphasized that determination of good faith is factual and not reviewable in petitions for review, particularly when trial and appellate courts unanimously found buyers acted in good faith.