In the Philippines, the Supreme Court’s decision in Uy v. Spouses Lacsamana clarifies how property rights are determined when a couple lives together without a valid marriage. The Court ruled that if a property is registered solely in one partner’s name and there is sufficient evidence to prove it was acquired using that partner’s personal funds, it is considered their separate property, even if they are living with another person as husband and wife. This means that the partner whose name is on the title can sell or dispose of the property without the other partner’s consent.
When ‘Married To’ Doesn’t Mean Shared Ownership: The Case of Uy vs. Spouses Lacsamana
The case revolves around a parcel of land in Batangas City, originally acquired by Petra Rosca, with the title indicating “Petra Rosca, married to Luis G. Uy.” Luis Uy filed a complaint seeking to nullify the sale of the land by Petra Rosca to Spouses Lacsamana, arguing that the property was conjugal and sold without his consent. Uy claimed he and Rosca were husband and wife, and the property was acquired during their marriage. The central legal question was whether the property belonged solely to Rosca as her paraphernal property, or if it was co-owned with Uy, requiring his consent for the sale.
To determine the validity of the sale, the Court had to first ascertain whether a valid marriage existed between Uy and Rosca. While there’s a legal presumption that a man and woman living together are married, this presumption can be overturned by evidence. Uy failed to provide a marriage certificate or any solid proof of a valid marriage. In fact, records showed that Uy himself had previously stated he was “not legally” married to Rosca in his petition for naturalization as a Filipino citizen. Because Uy could not prove that he was legally married to Rosca, the Supreme Court considered their property relations under Article 147 of the Family Code, which applies to couples living together without a marriage.
Article 147 states that properties acquired during cohabitation are presumed to be co-owned, unless proven otherwise. However, Rosca presented compelling evidence that the property was exclusively hers. A key piece of evidence was a resolution from the Land Registration Commission (LRC) recognizing Rosca as the sole registered owner. Furthermore, in the Deed of Sale where Rosca acquired the property from Spouses Manuel, Uy was merely a witness, suggesting he acknowledged Rosca’s sole ownership. Rosca also executed an Affidavit of Ownership stating she was the sole owner and that the phrase “married to Luis G. Uy” was simply a description of her status. The court emphasized that the title was registered in Rosca’s name alone. As the Supreme Court highlighted, the words “married to” are merely descriptive of Rosca’s civil status and do not automatically confer ownership to her partner.
The Court then addressed Uy’s argument that the sale was simulated due to lack of consideration. Uy claimed the Spouses Lacsamana did not prove they paid the P80,000 consideration, and even if they did, it was unconscionably low. However, Uy failed to provide any evidence to support these claims. He did not present any proof that Rosca didn’t receive the payment, nor did he offer evidence of the property’s fair market value at the time of the sale. As such, the Court upheld the validity of the sale. The Supreme Court emphasized that it is not a trier of facts and factual issues such as payment of purchase price cannot be raised in a petition for review on certiorari.
The Supreme Court reiterated the principle that its role is to review questions of law, not to re-evaluate the factual findings of lower courts. Since both the trial court and the Court of Appeals had thoroughly examined the evidence and found that Rosca had successfully proven her sole ownership of the property, the Supreme Court saw no reason to overturn their decisions. Ultimately, the Supreme Court sided with the respondents and upheld the validity of the sale. The Court underscored that the phrase “married to” in a property title does not automatically grant ownership rights to the spouse, especially when other evidence suggests that the property was acquired and owned exclusively by one party.
FAQs
| What was the key issue in this case? | The key issue was whether a property registered under the name of “Petra Rosca, married to Luis G. Uy” was Rosca’s exclusive property or co-owned with Uy, requiring his consent for its sale. |
| What happens to properties of couples who live together without marriage? | Under Article 147 of the Family Code, properties acquired during cohabitation are presumed to be co-owned unless there’s proof to the contrary, such as evidence showing the property was acquired solely by one partner. |
| What kind of evidence can prove separate ownership in such cases? | Evidence can include documents like the Deed of Sale, affidavits of ownership, and resolutions from the Land Registration Commission that show the property was acquired using one partner’s personal funds. |
| What does the phrase “married to” in a property title mean? | The phrase “married to” is generally considered descriptive of the person’s civil status and does not automatically confer ownership rights to the spouse unless there’s evidence of co-ownership. |
| Can a person sell a property registered solely in their name without their partner’s consent? | Yes, if the property is proven to be their separate property, they can sell it without the consent of their partner, even if they are living together as husband and wife. |
| What should I do if I’m buying property from someone who is cohabitating but not married? | Conduct a thorough title search and request documentation proving the seller’s sole ownership of the property to avoid future disputes regarding ownership rights. |
| How does this ruling impact unmarried couples in the Philippines? | This ruling highlights the importance of clearly documenting property ownership for unmarried couples to avoid disputes. It also underscores the importance of having an attorney help separate co-owned properties between unmarried individuals. |
| What happens if one party claims the sale was made without proper consideration? | The burden of proof lies on the party claiming lack of consideration to provide evidence showing that no payment was made or that the purchase price was unconscionably low. |
The Uy v. Spouses Lacsamana case serves as a crucial reminder of the significance of proper documentation in property ownership, especially for couples who are not legally married. It clarifies that the phrase “married to” in a property title is merely descriptive and does not automatically grant ownership rights. This underscores the need for individuals to ensure that their property rights are clearly defined and supported by evidence.
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: Luis Uy, substituted by Lydia Uy Velasquez and Shirley Uy Macaraig, vs. Spouses Jose Lacsamana and Rosaura Mendoza, substituted by Corazon Buena, G.R. No. 206220, August 19, 2015
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