Valdes v. RTC Branch 102
G.R. No. 122749 (July 31, 1996)
Facts:
Antonio A. S. Valdes and Consuelo M. Gomez-Valdes were married on January 5, 1971, and had five children during their marriage. On June 22, 1992, Valdes filed a petition for the declaration of nullity of their marriage, citing psychological incapacity as the ground under Article 36 of the Family Code. The Regional Trial Court of Quezon City, Branch 102, granted the petition on July 29, 1994, declaring the marriage null and void ab initio due to the mutual psychological incapacity of both parties.
The court's decision included provisions regarding the custody of their children, allowing the three older children to choose which parent to stay with, while the younger two were placed in the custody of their mother. The court also directed both parties to initiate proceedings for the liquidation of their common properties as defined by Article 147 of the Family Code.
Following the decision, Consuelo Gomez sought clarification regarding the liquidation of their common property, arguing that the Family Code did not provide a procedure for the liquidation of common property in "unions without marriage." In response, the trial court clarified that under Article 147, properties acquired during their union were presumed to be owned in equal shares, and the rules on co-ownership from the Civil Code would apply.
Valdes filed a motion for reconsideration, which was denied. He contended that Articles 50, 51, and 52 of the Family Code should govern the disposition of the family dwelling in cases of void marriages, including those declared void due to psychological incapacity.
Legal Issues:
- Whether the trial court correctly applied the law regarding the disposition of the family dwelling and common properties in a case where a marriage is declared void ab initio due to psychological incapacity.
- Whether Articles 50, 51, and 52 of the Family Code are applicable in the liquidation of properties in such cases.
Arguments:
Petitioner (Valdes):
- Argued that Articles 50, 51, and 52 of the Family Code should govern the disposition of the family dwelling in cases of void marriages.
- Contended that Article 147 does not apply to marriages declared void ab initio due to psychological incapacity.
- Suggested that the trial court's ruling did not adequately consider the best interests of the children regarding custody.
Respondent (Gomez):
- Asserted that the trial court's clarification regarding the application of Article 147 was correct.
- Maintained that the property regime should be governed by the rules on co-ownership as stipulated in the Civil Code, given the declaration of nullity of the marriage.
Court's Decision and Legal Reasoning:
The Supreme Court affirmed the trial court's orders, holding that the property relations of parties in a void marriage are governed by Article 147 of the Family Code. The Court reasoned that Article 147 applies to both void marriages and unions without marriage, establishing a regime of co-ownership for properties acquired during the relationship.
The Court emphasized that the provisions of Articles 50, 51, and 52, which pertain to the liquidation of properties in valid and voidable marriages, do not apply to the situation of common-law spouses or those in void marriages. The Court clarified that the rules on co-ownership under the Civil Code are appropriate for the liquidation of properties in such cases.
The Court also noted that the trial court acted within its jurisdiction to resolve incidental matters related to the declaration of nullity, including the liquidation of common properties. The ruling reinforced the principle that properties acquired during cohabitation are presumed to be owned equally unless proven otherwise.
Significant Legal Principles Established:
- Article 147 of the Family Code governs the property relations of parties in a void marriage, establishing a regime of co-ownership for properties acquired during the relationship.
- The provisions for the liquidation of properties in valid and voidable marriages (Articles 50, 51, and 52) do not apply to void marriages or unions without marriage.
- The trial court has the authority to resolve incidental matters, such as the liquidation of common properties, when declaring a marriage null and void.