<Persons> < Francisco vs Spouses Gonzales> <Alec Vega>

CASE DIGEST
Francisco vs Spouses Gonzales
G.R. No. 177667
Austria-Martinez J.

FACTS
 Petitioners Cleodia and Ceamantha are the minor children of Cleodualdo and Michele who had their marriage
annulled.
 The parents entered into a Compromise Agreement wherein a dissolution of the Conjugal Partnership of Gains
which transfers their property located in Ayala Alabang to the petitioners by way of a deed of donation upon
reaching the age of majority.
 Meanwhile, in a case for Unlawful Detainer filed by Sps.Gonzales against Matrai and Michele was decided and
ordered the latter to vacate the property leased to them and pay the unsettled obligations.
 The latter case caused a writ of execution upon the property subject of the Compromise Agreement,.
 The grandmother acting as guardians of the minors filed a motion to stop the sale of the property, but was
denied.
 She then appealed to the CA, but pending the appeal the RTC in the earlier case granted the issuance of a new
certificate of title and for the issuance of the writ of possession. The CA ultimately denied the appeal, hence the
case at bar.
 Petitioners contend that: (1) they are the rightful owners of the property in Ayala Alabang as the Compromise
Agreement in the annulment case has become final; (2) the parents already waived their rights to the property
through the Compromise Agreement; (3) Michele’s obligations did not benefit the entire family; (4) the
obligation stemmed from a joint effort from Michele and Matrai

ISSUES ARTICLES/LAWS INVOLVED

1. WON the property subject of the compromise Family Code
agreement can be used to satisfy Michele and
Matrai’s obligations to Sps. Gonzales?

HELD
 <Persons> < Francisco vs Spouses Gonzales> <Alec Vega>
No.

Debts should be paid by the debtor alone. In this case, the property was part of the conjugal partnership of gains as it
was acquired after Cleodualdo and Michele’s wedding. While the lower court recognized that the property was conjugal,
it held reasoning that the debt incurred by Michele was not proven not to be of benefit to the family. This is not the
case. The obligation stemmed from an Unlawful detainer case filed against Michele and her partner Matrai, it couldn’t
have benefited the family.

While it is the lower court’s duty to make sure that debts be paid, it must make sure that the property in question can be
executed upon. In this case, Michele’s lone obligation cannot be charged against the conjugal property of gains because
the obligation did not redound to the benefit of the family.

Petition Granted