LUIS UY, SUBSTITUTED BY LYDIA UY VELASQUEZ AND SHIRLEY UY MACARAIG, Petitioner, v.

SPOUSES
JOSE LACSAMANA AND ROSAURA* MENDOZA, SUBSTITUTED BY CORAZON BUENA, Respondents. G.R.
No. 206220, August 19, 2015

Facts:

The subject of the litigation involves a parcel of land known as Lot 5506 of the Cadastral Survey of
Batangas plan. The land, situated in Barrio Alangilan, Batangas City, contains an area of 484 square
meters under Transfer Certificate of Title (TCT) No. T-24660. On 4 May 1979, petitioner Luis Uy (Uy) filed
with the Regional Trial Court (RTC) of Pallocan West, Batangas City, Branch 4, a Complaint5 for
Declaration of Nullity of Documents with Damages against respondents Petra Rosca (Rosca), and
spouses Jose Lacsamana and Rosaura Mendoza (Spouses Lacsamana).

Uy alleged that he was the lawful husband of Rosca. That they lived together as husband and wife from
the time they were married in 1944 until 1973 when they separated and lived apart. Uy and Rosca had
eight children. Uy and Rosca acquired the lot on 29 January 1964 a 484 square meter residential land for
a consideration of P1,936 evidenced by a Deed of Sale from the previous owner. he sellers' OCT No. 0-
2840 was cancelled and TCT No. T-24660 was issued in the name of "Petra Rosca, married to Luis G. Uy."

On 15 June 1964, Uy and Rosca allegedly purchased another residential land adjacent to the 484 square
meter land consisted of 215 square meters, as declared under Tax Declaration No. 61724, for a
consideration of P700.

Uy alleges, among others, that the property that is part of the sale of Rosca to spouses Lacsamana was
void for failure to obtain his marital consent, the property being conjugal in nature. Uy then filed a
complaint praying that the Deed of Sale executed by Rosca in favor of spouses Lacsamana be declared
null and void with respect to his rights, interest, ownership and damages. Rosca however contends that
since the property in question was registered in Rosca's name, such circumstance indicated that the
property belonged to Rosca, as her paraphernal property from her paraphernal funds and that she was
never married to Uy. Upon Uy’s death his two daughters, Lydia Uy Velasquez and Shirley Uy Macaraig
substituted him in the case. Years later, Rosca also died. Earlier, respondent Jose Lacsamana died on 20
March 1991. Meanwhile, Spouses Lacsamana sold the property to Corazon Buena through a Deed of
Absolute Sale. Thus, both Rosca and the Spouses Lacsamana were substituted by Buena as respondent
in this case.

Issue:
Whether the Deed of Sale executed by Rosca alone, without Uy's consent, in favor of Spouses
Lacsamana, is valid.

Ruling:
Yes, the sale is valid.
Under the law, when a man and a woman who are capacitated to marry each other, live exclusively with
each other as husband and wife without the benefit of marriage or under a void marriage, their wages
and salaries shall be owned by them in equal shares and the property acquired by both of them through
their work or industry shall be governed by the rules on co-ownership.