**Facts:**
This dispute revolves around a piece of land in San Jose, Tarlac, registered under Transfer Certificate of Title No. 56899 in the names of Juan F. Coloma and his wife Juliana Parazo, who are both deceased. Their heirs, after the demise of Juan and Juliana, found the property in possession of Spouses Romeo Anastacio, Sr. and Norma T. Anastacio (the petitioners), who claimed ownership via an alleged Deed of Absolute Sale executed by Juan. The heirs’ request for the surrender of possession led to a legal battle, starting with a case for Recovery of Possession and Title at the Municipal Circuit Trial Court (MCTC) which was dismissed and recommended for filing in a higher court due to the ownership claim.
The heirs then filed a Complaint for Annulment of Document, Recovery of Ownership and Possession with the Regional Trial Court (RTC) of Camiling, Tarlac, challenging the validity of the Deed of Absolute Sale on grounds of forgery and lack of consent from Juliana. The RTC ruled in favor of the Anastacios, declaring the deed valid and recognizing the property as Juan’s exclusive property. Upon appeal, the Court of Appeals (CA) reversed the RTC’s decision, finding the sale void due to the forged signature of Juan and the failure to secure Juliana’s consent, considering the property as conjugal.
**Issues:**
1. Whether Juan’s signature in the Deed of Absolute Sale was forged.
2. Whether the CA erred in setting aside the presumption of regularity of the notarized Deed of Absolute Sale.
3. Whether the subject property is conjugal, thus requiring Juliana’s consent for its sale.
4. Whether the Anastacios were good faith buyers of the subject property.
**Court’s Decision:**
The Supreme Court upheld the CA’s findings and denied the petition. It clarified that:
– The issue of forgery, while reviewed, was rendered moot since the sale would be void regardless due to the absence of Juliana’s consent.
– The presumption of regularity in the notarization and execution of the Deed does not override evidence of forgery and absence of conjugal consent.
– With the property acquired during Juan and Juliana’s marriage and registered in Juan’s name but describing him as married to Juliana, the property is presumed conjugal. The Anastacios failed to overcome this presumption.
– The Anastacios were not considered buyers in good faith as they should have been more diligent, especially knowing Juan and Juliana’s separation.
**Doctrine:**
– The family code stipulates that properties acquired during the marriage are presumed conjugal unless proven otherwise, and their disposition requires the consent of both spouses.
– A deed of sale of property presumed conjugal, without the consent of one spouse, is void.
– Good faith acquisition requires diligence in verifying the authority to sell conjugal property.
**Class Notes:**
– **Conjugal Property Presumption**: All property acquired during the marriage is presumed to be conjugal unless proven otherwise (Family Code, Art. 116).
– **Void Transactions**: Sale of conjugal property without the consent of both spouses is void (Family Code, Art. 124).
– **Good Faith in Property Acquisition**: Buyers must exercise due diligence in verifying the authority to sell, especially concerning conjugal properties.
**Historical Background:**
The case exemplifies the complexity of property disputes involving alleged sales by one spouse, forgery claims, and the crucial need for both spouses’ consent for the disposal of conjugal property. It highlights the transition and application of family law principles from the Civil Code to the Family Code, emphasizing protections around conjugal property and the requisites for its valid disposition.
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