JUAN SEVILLA SALAS, Petitioner vs EDEN VILLENA SALAS, Respondent

FACTS:
On September 1985, Juan Salas and Eden Salas were married. Salas left the conjugal dwelling
and he no longer communicated with Aguila and to his daughter. On 2003, Aguila filed a
petition for the Declaration of Nullity of their marriage citing psychological incapacity and on
2007, the RTC rendered decision declaring the nullity of their marriage and the dissolution of
their conjugal property if any. On 2007, Aguila discovered two (2) parcels of land registered to
Juan Salas married to Rubina Salas as evidenced to the discovered properties of her. Aguila filed
a Manifestation and Motion on her discovered properties.
ISSUE: Whether or not the petition of Aguila on partition of conjugal properties be granted even
after the declaration of nullity of marriage.
HELD:
RTC RULING: The petition was granted in favor of Aguila. RTC held that pursuant to the Rules of
Court, even upon entry of judgment granting the annulment of marriage, the court can proceed
with the liquidation, partition, and distribution of the conjugal partnership of gains if it has not
been adjudicated upon, as in this case.
THE CA RULING:
The CA affirmed the order of RTC. The CA ruled that Aguilas statement in her petition is not a
judicial admission because the petition was filed on October 2003 and she only discovered the
property on April 17, 2007 prior to the promulgation of the RTC decision. Thus, the CA ruled
that Aguila was palpably mistaken in her petition and it would be unfair to punish her over a
matter that she had no knowledge of at the time she made the admission. In this case, where
the ground for nullity of marriage was psychological incapacity, we held that the properties
acquired during the union of the parties, as found by both the RTC and CA, would be governed
by co-ownership as sustained by the RTC and the CA.