MEDINA v COLLECTOR OF INTERNAL REVENUE PARTIES TO SALE

FACTS:
- 1944: Petitioner Antonio Medina marries Antonia Rodriguez. Neither have any property of their own.
- Eventually, they were able to get a logging concession.
- Antonia Rodriguez (wife) then opens a lumber dealer shop. Up to 1952, Antonio Medina (husband) sold
all his logs from the concession to her. Antonia Rodriguez (wife) then sells the logs in Manila through an
agent who then gives the proceeds back to the husband.
- Collector of Internal Revenue, stating that the sale between spouses is void, taxed Antonio Medina
(husband) on the sales of Antonia Rodriguez (wife)
- Petitioner protested taxing, stating that he should only be taxed on his sale to his wife.
- Petitioner offers testimony (no document) that they entered a regime of separation of property prior to
their marriage.
ISSUE:
WoN the sale of Antonio Medina (husband) to Antonia Rodriguez (wife) is void
RULING:
- YES, sale is void between the spouses. The petitioner only offered testimonial evidence to support his
assertions. The factual findings of the court finds the impossibility of the narration. Primarily, the husband
and wife could have not entered into a regime of separation of property prior to the marriage when they
never had property before it.
- Contracts violative of the provisions of Article 1490 of the Civil Code are null and void. Being void
transactions, the sales made by the petitioner to his wife were correctly disregarded by the Collector in his
tax assessments that considered as the taxable sales those made by the wife through the spouses'
common agent, Mariano Osorio. In upholding that stand, the Court below committed no error.