Alfonso Garcia v. Carmen Garcia

CourtCourt of Appeals of Texas
DecidedAugust 2, 2012
Docket02-11-00276-CV
StatusPublished

This text of Alfonso Garcia v. Carmen Garcia (Alfonso Garcia v. Carmen Garcia) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alfonso Garcia v. Carmen Garcia, (Tex. Ct. App. 2012).

Opinion

02-11-276-CV

COURT OF APPEALS

SECOND DISTRICT OF TEXAS

FORT WORTH

NO. 02-11-00276-CV

Alfonso Garcia

APPELLANT

V.

Carmen Garcia

APPELLEE

----------

FROM THE 324th District Court OF Tarrant COUNTY

MEMORANDUM OPINION[1]

Introduction

Appellant Alfonso Garcia appeals the trial court’s finding of an informal marriage[2] between him and appellee Carmen Garcia and its division of the community property.  We affirm.

Factual Background

The Garcias divorced in 1989 but resumed living together in September 1990.  The couple continued living together until November 2008.  Throughout this period, Alfonso visited Mexico every year.  Around 2003, during one of his visits to Mexico, he met a woman named Maria Sanchez.  Alfonso began a relationship with Sanchez but never told Carmen about her.

In February 2008, Alfonso finally confessed to Carmen that he had met someone in Mexico.  Alfonso said that Sanchez was pregnant, and he wanted to marry her.  Alfonso and Carmen continued to live together.  In July 2008, Alfonso went back to Mexico and married Sanchez in a civil court.[3]  When he returned, Carmen tried to prevent him from returning to their home, but he told her that he had the legal right to do so.  Alfonso continued living with Carmen until November 2008, when he left again for Mexico.  Alfonso and Sanchez had a Catholic wedding ceremony on December 31, 2008, in Mexico.  Alfonso returned alone to Texas in January 2009, but this time Carmen refused to let him in the house.  She filed for divorce on February 26, 2009, on the grounds of adultery and conflict of personalities.

The couple owned three Texas properties: (1) 3414 Strong Avenue; (2) 1207 Minden Street;[4] and (3) 1006 East Cantey Street.  According to testimony, from 1990 to 1996 they lived at the Strong Avenue property.  In 1996, the couple purchased the property on Minden Street; after renovations, they moved into that home and resided there from 1999 until their separation in 2008.  Alfonso used the house on East Cantey Street as rental property.[5]  Carmen testified that Alfonso retained the $500-a-month rental payments.  At the time Carmen filed for divorce, Alfonso was living at the Strong Avenue property.  Prior to the hearing, Alfonso transferred two of these properties that belonged to the community estate to his nephew, Mario Martinez, without Carmen’s permission.

During the trial, there was some dispute regarding property purchased by Alfonso in Mexico.  Carmen testified that from 1994 through 1996 Alfonso purchased two lots in Mexico and that he was paying taxes on them.  However, Alfonso testified that he had never purchased property in Mexico, but had inherited property from his father that belonged collectively to Alfonso and his siblings.

The trial court found that the Garcias were married on or about September 1, 1990, and ceased living together on or about November 27, 2008.  Further, the trial court found that the couple had an informal marriage during the entirety of that time.  The trial court found that Alfonso had committed adultery and granted the divorce.  It also ordered the properties transferred back to Alfonso and Carmen jointly so that they may be divided at a later hearing.

At the final hearing for the division of the property, the trial court awarded Carmen all of the property associated with the Minden Street address and the property located on East Cantey Street.  Alfonso was awarded the property on Strong Avenue.  Because there was no proof of any property purchased by Alfonso in Mexico, the trial court found that Alfonso was entitled to any land inherited from his father; however, any land purchased by Alfonso would be awarded to Carmen.  Alfonso filed a motion for a new trial arguing that the disproportionate division of property was an abuse of discretion, but he did not challenge the trial court’s finding that there was an informal marriage.[6]  Alfonso then filed this appeal.

Discussion

A.  Common Law Marriage

In his first issue, Alfonso argues that the evidence is legally and factually insufficient to support the trial court’s finding that he and Carmen were informally married.  However, in family law cases, the abuse of discretion standard of review overlaps with the traditional sufficiency standard of review; thus, legal and factual insufficiency are not independent reversible grounds of error but are relevant factors in assessing whether the trial court abused its discretion.  Neyland v. Raymond, 324 S.W.3d 646, 649 (Tex. App.—Fort Worth 2010, no pet.); Boyd v. Boyd, 131 S.W.3d 605, 611 (Tex. App.—Fort Worth 2004, no pet.).

In a bench trial in which no findings of fact or conclusions of law are filed, the trial court’s judgment implies all findings of fact necessary to support it.  Pharo v. Chambers County, 922 S.W.2d 945, 948 (Tex. 1996); In re Estate of Rhea, 257 S.W.3d 787, 790 (Tex. App.—Fort Worth 2008, no pet.).  But when a reporter’s record is filed, these implied findings are not conclusive, and an appellant may challenge them by raising issues challenging the sufficiency of the evidence.  BMC Software Belg., N.V. v. Marchand, 83 S.W.3d 789, 795 (Tex. 2002); Estate of Rhea, 257 S.W.3d at 790.

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Bluebook (online)
Alfonso Garcia v. Carmen Garcia, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alfonso-garcia-v-carmen-garcia-texapp-2012.