- Petitioner
- Belinda Alexander
- Respondent
- Spouses Jorge
- Citation
- G.R. No. 256141
- Court
- Supreme Court En Banc
- Division
- En Banc
- Ponente
- M.V. Lopez, J.
- Decided
- July 19, 2022
Summary
This Supreme Court case clarifies the applicable law for conjugal property transactions without spousal consent. Spouses Escalona, married under the Civil Code, owned conjugal lots that Jorge transferred to son Reygan and subsequently to Belinda Alexander without wife Hilaria's consent. The Court established that the applicable law depends on the date of alienation, not marriage - transactions after Family Code effectivity are governed by Article 124 making them void without spousal consent. The Court declared Lot No. 1 transactions void under Family Code and Lot No. 2 transactions inexistent under Civil Code for lack of proper consent. While upholding the nullity of all transactions, the Court ordered reimbursement to prevent unjust enrichment, harmonizing previous conflicting jurisprudence on conjugal property alienations.
Intellegal Wiki · Key Holding
Partly granted the petition, holding that the law governing alienation of conjugal property depends on the date of the transaction, not the marriage: transactions after the Family Code's effectivity are void without spousal consent under Article 124, while an earlier one was inexistent under Civil Code Article 1318; reimbursement was ordered to prevent unjust enrichment.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.