The Supreme Court’s decision in Rosario Banguis-Tambuyat v. Wenifreda Balcom-Tambuyat clarifies the rights of a legal spouse over property acquired during a valid marriage. This case emphasizes that only a legally recognized spouse can be designated as such in property titles. The ruling protects the legitimate spouse’s claim to property acquired during the marriage, preventing other parties from unlawfully claiming marital rights and property ownership.

When Love and Law Collide: Who Is the Rightful Spouse in Property Ownership?

The case revolves around a dispute over a property in Bulacan acquired during the marriage of Adriano Tambuyat and Wenifreda Balcom-Tambuyat. The property’s title, however, erroneously indicated “Adriano M. Tambuyat married to Rosario E. Banguis” despite Rosario Banguis-Tambuyat being married to another person at the time. Wenifreda filed a petition to cancel the title and have it reissued in her name as the legal spouse. Rosario, on the other hand, opposed the petition, claiming she was Adriano’s wife and that the property was purchased using her personal funds. The central legal question was whether the court could correct the title under Section 108 of Presidential Decree No. 1529 (PD 1529), also known as the Property Registration Decree, given Rosario’s serious objections.

The Regional Trial Court (RTC) ruled in favor of Wenifreda, ordering the cancellation of the erroneous title and the issuance of a new one reflecting her as Adriano’s spouse. The Court of Appeals (CA) affirmed this decision, leading Rosario to elevate the case to the Supreme Court. The Supreme Court, in affirming the CA’s decision, emphasized that proceedings under Section 108 of PD 1529 are appropriate for correcting clerical errors or mistakes in certificates of title. Section 108 of PD 1529 outlines the instances where a certificate of title can be amended or altered:

Section 108. Amendment and alteration of certificates. No erasure, alteration, or amendment shall be made upon the registration book after the entry of a certificate of title or of a memorandum thereon and the attestation of the same by the Register of Deeds, except by order of the proper Court of First Instance.

The Court found that the inclusion of Rosario’s name as Adriano’s spouse was indeed an error, as Wenifreda was the legally recognized wife. This case fell under the provisions allowing correction of errors or when reasonable grounds for amendment exist. Building on this principle, the Court addressed Rosario’s claim that the RTC lacked jurisdiction due to the contentious nature of the dispute. The Supreme Court held that Rosario had acquiesced to the RTC’s jurisdiction by actively participating in the proceedings and presenting evidence to support her claims. The Court noted that:

“The active participation of the party against whom the action was brought, coupled with his failure to object to the jurisdiction of the court or quasi-judicial body where the action is pending, is tantamount to an invocation of that jurisdiction and a willingness to abide by the resolution of the case and will bar said party from later on impugning the court or body’s jurisdiction.”

This principle prevents parties from challenging a court’s jurisdiction after having actively participated in the proceedings. Further, the Supreme Court highlighted the legal principle that Philippine law does not recognize common-law marriages for the purpose of spousal rights in property ownership, except in specific instances outlined in Article 144 of the Civil Code. The Court quoted:

We hold that the provisions of the Civil Code, unless expressly providing to the contrary as in Article 144, when referring to a “spouse” contemplate a lawfully wedded spouse.

The Court dismissed Rosario’s argument that Article 148 of the Family Code should apply, which governs the division of properties acquired by individuals in a defective marriage. Since both Adriano and Rosario were married to other people at the time of their relationship, their situation did not qualify under Article 148. The Supreme Court emphasized the distinction between ownership and the certificate of title, stating that registration does not vest title but merely serves as evidence of it. As the Court elucidated:

Registration does not vest title; it is merely the evidence of such title. Land registration laws do not give the holder any better title than what he actually has.

The Court thus clarified that even if Rosario claimed to have contributed to the purchase of the property, it did not automatically grant her the right to be designated as Adriano’s spouse in the title. The Court was not convinced by Rosario’s claim of ownership, noting the deed of sale indicated Adriano as the sole vendee and that she failed to present sufficient proof of financial contribution. In sum, the Supreme Court’s decision underscores the importance of legal marriage in determining spousal rights over property. It clarifies the application of Section 108 of PD 1529 for correcting errors in property titles and affirms the principle that only legally married spouses are entitled to be designated as such in property titles. This ruling serves to protect the rights of legitimate spouses and prevent unlawful claims based on informal relationships.

FAQs

What was the key issue in this case?	The key issue was whether the court could correct an error in a property title to reflect the rightful spouse when the title erroneously named another person. The court also addressed the jurisdiction issue raised by the petitioner.
Who was the legitimate spouse in this case?	Wenifreda Balcom-Tambuyat was the legitimate spouse of Adriano Tambuyat, as evidenced by their marriage contract. Rosario Banguis-Tambuyat was married to another person, Eduardo Nolasco, at the time the property was acquired.
What is Section 108 of PD 1529?	Section 108 of PD 1529, also known as the Property Registration Decree, allows for the amendment or alteration of certificates of title under certain circumstances. These circumstances include correcting errors or omissions in the title.
Can a common-law spouse be designated in a property title?	Generally, Philippine law does not recognize common-law marriages for the purpose of spousal rights in property ownership. Only legally married spouses are entitled to be designated as such in property titles.
What happens if a property is acquired during a relationship where both parties are married to others?	Article 148 of the Family Code does not apply in such cases. The law requires a valid or voidable marriage for its provisions to govern property division; therefore, the property will be adjudicated based on evidence of actual contribution to the purchase of the property.
What is the difference between ownership and a certificate of title?	Ownership refers to the actual right to possess and use property, while a certificate of title is merely evidence of that ownership. Registration does not vest title but serves as the best proof of ownership.
What was the basis for the Court’s decision?	The Court based its decision on the evidence presented, which showed that Wenifreda was the legitimate spouse of Adriano. The Court also considered the fact that Rosario was married to another person and had not presented sufficient proof of financial contribution to the property purchase.
What is the significance of acquiescing to a court’s jurisdiction?	When a party actively participates in court proceedings without objecting to the court’s jurisdiction, they are considered to have acquiesced to that jurisdiction. This prevents them from later challenging the court’s authority.

This case provides a clear legal framework for determining spousal rights in property ownership. The Supreme Court’s decision serves as a reminder of the importance of legal marriage and the need for accurate information in property titles. It reinforces the principle that only legally recognized spouses can claim spousal rights over property acquired during a valid marriage. For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Rosario Banguis-Tambuyat v. Wenifreda Balcom-Tambuyat, G.R. No. 202805, March 23, 2015