People Bank v. The Register of Deeds For the City of Manila

Summary

This 1934 Supreme Court En Banc decision established that a married woman can create a trust over her paraphernal property and authorize rent collection without her husband's consent. Dominga Angeles executed a trust agreement with Peoples Bank and Trust Co. for property subdivision and management, but registration was denied for lack of marital consent. The Supreme Court reversed, holding that under Civil Code article 1384, wives have management authority over paraphernal property unless formally delivered to husbands. Authorizing rent collection constitutes administration, not alienation. Lack of marital consent makes contracts voidable rather than void, and only husbands or heirs can challenge them. The decision clarified married women's property management rights and affirmed that voidable contracts remain registrable, significantly advancing women's property rights in Philippine jurisprudence.