HEIRS OF IGNACIA AGUILAR-REYES vs.

SPOUSES CIPRIANO MIJARES and

FLORENTINA MIJARES[G.R. No. 143826. August 28, 2003.]
YNARES-SANTIAGO
FACTS:
In 1960, Vicente Reyes married Ignacia Aguilar but they had been separated de facto
in1974. One of their conjugal properties is Lot No. 4349 B-2 and the apartment built thereon. Thesaid lot
was registered in the name of Spouses Vicente Reyes and Ignacia Aguilar-Reyes.Vicente Reyes fi led a
petition for administration and appointment of guardian with theMTC. In the said petition, he
misrepresented that his wife, Ignacia, died on March 12, 1982 and that he and their minor children
were her only heirs. The court appointed Vicente as guardian oftheir minor children and subsequently
authorized Vicente to sell the estate of Ignacia. On March 1,1983, respondent Spouses Cipriano and
Florentina Mijares bought Lot No. 4349-B-2 for P110,000. Asa consequence of which, the certificate of
title in the name of Vicente and Ignacia Agilar-Reyes wascancelled and a new title was issued in the name
of respondent-spoues. These circumstances werediscovered by Ignacia sometime in 1984.Ignacia then
sent a letter to respondent-spouses demanding the return of her share in the lot. Failing to
settle the matter amicably, Ignacia instituted a complaint for annulment of saleagainst respondentspouses and Vicente was included as one of the defendants. In their answer,respondents claimed that
they are purchasers in good faith and that the sale was valid because thesame was duly approved by the
court.After trial on the merits, the court a quo rendered a decision declaring the sale of Lot No.4349-B-2
void with respect to the share of Ignacia. A motion for modification of the decision wasfiled by Ignacia
praying that the sale be declared void in its entirety and that the respondents beordered to reimburse the
rentals collected on the apartments. The trial court granted the motionfor
modification.B oth I g n a ci a a n d re sp o n d e n t -s p o u se s a p p e a le d to t h e
C o u r t o f A p p e a l s. Pe n d in g t h e appeal, Ignacia died and was substituted by her compulsory
heirs. The appellate court reversedthe decision of the ocurt a quo, ruling that, notwithstanding the
absence of Iganacias consent tothe sale, the same must be held valid in favor of respondent-spouses
because they were innocentpurchasers for value.
ISSUES:
1. What is the status of the sale of Lot No. 4349-B-2 to respondent-spouses?2. Would the sale,
if voidable, be annulled in its entirety?3. Were respondent-spouses purchasers in good faith?
HELD:
1.
VOIDABLE.
Pursuant to the foregoing provisions (Articles 166 and 173 of the Civil Code),the husband could not
alienate or encumber any conjugal real property without the consent, express or implied, of the
wife otherwise, the contract is voidable. Indeed, in several cases th