Spouses Eulalio Cueno v. Spouses Epifanio

Summary

This landmark Supreme Court case resolved a long-standing conflict in jurisprudence regarding the validity of conjugal property sales without spousal consent. The Court definitively ruled that under Civil Code Articles 166 and 173, such sales are merely voidable, not void, abandoning previous inconsistent rulings. The wife must file an action for annulment during the marriage and within ten years from the questioned transaction. Since petitioner Flora failed to exercise this right within the prescribed period (the 1963 sale was challenged only in 2009), her action had prescribed. The Court distinguished this from the Family Code regime which makes such transactions void, demonstrating the evolution of conjugal property law in protecting spousal rights while providing certainty in property transactions.