Valdez vs RTC Facts: The petitioner Valdez sought a petition for review to the SC in is pursuit to reverse/modify the decision

of the trial court regarding the liquidation of conjugal/community property. Valdez first sought for judicial declaration of nullity against his marriage to Consuelo Gomez on the ground of psychological incapacity, in virtue of article 36. The trial court granted the declaration of nullity and ordered the commencement of the proceedings on liquidation of their common properties. The court held that article 149 shall be employed with compliance to article 50, 51 and 52. The petitioner appealed but to no avail. Distasted with the decision, the petitioner argued in this petition that article is 149 is not the appropriate law in the case at bar, regarding liquidation of common properties, because it does not expressly nor impliedly aver that it will be applied in cases where the parties are psychologically incapacitated. The petitioner furthered that article 50, 51 and 52 in relations to article 102 shall be more in consonance to cases where psychological incapacity is the grounds for voiding marriage. Hence, this recourse.

WON article 149 shall apply in cases where there is property liquidation due to a void marriage on account of psychological incapacity

Held: The SC held that that in a void marriage, regardless of its cause, the property relations of the parties during the period of cohabitation is governed either by article 147 or article 148 of the Family Code. Article 147 of the Family Code applies to union of parties who are legally capacitated and not barred by any impediment to contract marriage, but whose marriage is nonetheless void, such as petitioner and respondent in the case before the Court. The law that must be applied to the case at bar is article 147 which bring forth the settlement of property regimes under void marriages and states that wages and salaries shall be owned by the parties in equal shares and their common property shall be governed by the rule of co ownership. On the other hand, article 50 states that in marriages which are declared ab initio or annulled by final judgment under Articles 40 and 45, the final judgment in such cases shall provide for the liquidation, partition and distribution of the properties of the spouses, the custody and support of the common children, and the delivery of third presumptive legitimes, unless such matters had been adjudicated in previous judicial proceedings. The first paragraph of article 50 of the Family Code, applying paragraphs 2, 3, 4 and 5 of article 43, relates only, by its explicit terms, to voidable marriages. The trial court, according to the SC, acted neither imprudently nor precipitately in adjudicating the case and found no reversible error in its decision. (Refer to your NCC codal because it gets pretty confusing)