Antonio A.S. Valdes vs. Regional Trial Court, Branch 102, Quezon City, and Consuelo M. Gomez-Valdes, G.R. No. 117222
### Facts:
Antonio Valdes and Consuelo Gomez were married on January 5, 1971, and had five children during the marriage. On June 22, 1992, Valdes filed a petition for the declaration of nullity of their marriage under Article 36 of the Family Code, citing mutual psychological incapacity. The case was docketed as Civil Case No. Q-92-12539 at the Regional Trial Court of Quezon City, Branch 102.
After a hearing, the trial court declared the marriage void ab initio on July 29, 1994, due to mutual psychological incapacity. The court also directed the parties to start proceedings for the liquidation of their common properties per Article 147 of the Family Code.
Consuelo Gomez later sought clarification regarding the liquidation process, arguing that the Family Code did not provide procedures for “unions without marriage.” The trial court clarified that the provisions on co-ownership in the Civil Code would govern the disposition of their common properties, which included the family home.
Antonio Valdes moved for reconsideration of the order, which the trial court denied on October 30, 1995. Valdes then elevated the case to the Supreme Court, principally questioning the applicability of Articles 50, 51, and 52 of the Family Code.
### Issues:
1. Whether Article 147 of the Family Code applies to cases where the marriage is declared void ab initio due to psychological incapacity.
2. Whether Articles 50, 51, and 52, in relation to Articles 102 and 129 of the Family Code, govern the disposition of properties in cases where a marriage is declared void ab initio.
### Court’s Decision:
The Supreme Court affirmed the orders of the trial court.
1. **Article 147 of the Family Code Applicability**:
– **Court’s Ruling**: The Court held that Article 147 of the Family Code, which governs the property relations between parties in a void marriage, applies in cases where the marriage is declared void ab initio due to psychological incapacity. Article 147 is a continuation of Article 144 of the Civil Code and addresses the co-ownership of properties acquired through joint effort during a void marriage.
– **Analysis**: The Article provides that properties acquired through joint efforts during cohabitation shall be equally owned. The Court pointed out that Article 147 covers property acquired by both parties’ work or industry, with care for the family considered a joint effort. Therefore, the court ruled it correctly applied Article 147.
2. **Applicability of Articles 50, 51, and 52 in Conjunction with Articles 102 and 129**:
– **Court’s Ruling**: The Court concluded that Articles 50, 51, 52, 102, and 129 apply to valid marriages or voidable marriages until annulment but do not apply to void marriages like the one in question. In a void marriage, property liquidation and partition are governed by ordinary co-ownership rules.
– **Analysis**: The Court held that statutory provisions on absolute community or conjugal partnership liquidation don’t apply to void marriages. Instead, co-ownership laws govern the disposition of properties acquired during the void marriage, as underlined in Article 147 of the Family Code.
### Doctrine:
1. **Article 147 of the Family Code governs the property relationship in void marriages**.
– This article covers property acquired by both parties’ joint efforts in void marriages, assuming equal ownership and requiring mutual consent for transactions during cohabitation.
2. **Liquidation of properties in void marriages follows co-ownership rules under the Civil Code**.
– The legally established property relations in valid and voidable marriages do not apply to void marriages; co-ownership provisions prevail instead.
### Class Notes:
– **Article 147 of the Family Code**:
– Properties acquired during cohabitation are considered co-owned.
– Equal shares are presumed.
– Mutual consent is necessary for transactions affecting co-owned property.
– **Co-Ownership under the Civil Code**:
– Ordinary rules of co-ownership apply.
– Properties are liquidated equitably according to actual contributions unless otherwise agreed.
– **Invalid Marriages**:
– No conjugal partnerships exist.
– Property acquired jointly during cohabitation is governed by co-ownership laws.
### Historical Background:
The Philippine Family Code enacted provisions like Article 147 to address property relations in marriages declared void ab initio. Article 36, introducing psychological incapacity as a ground for nullity, seeks to reflect modern understandings of marital capabilities. This landmark decision illustrates the practical application of these provisions in contemporary family law, ensuring equitable division of properties despite the void status of marriage.
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