- 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.