Vicki A. Gil v. John R. Holderman

CourtCourt of Appeals of Texas
DecidedAugust 15, 2018
Docket04-17-00701-CV
StatusPublished

This text of Vicki A. Gil v. John R. Holderman (Vicki A. Gil v. John R. Holderman) 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
Vicki A. Gil v. John R. Holderman, (Tex. Ct. App. 2018).

Opinion

Fourth Court of Appeals San Antonio, Texas MEMORANDUM OPINION

No. 04-17-00701-CV

Vicki A. GIL, Appellant

v.

John R. HOLDERMAN, Appellee

From the 224th Judicial District Court, Bexar County, Texas Trial Court No. 2013-CI-20199 Honorable Renée Yanta, Judge Presiding

Opinion by: Luz Elena D. Chapa, Justice

Sitting: Rebeca C. Martinez, Justice Patricia O. Alvarez, Justice Luz Elena D. Chapa, Justice

Delivered and Filed: August 15, 2018

AFFIRMED

Vicki A. Gil, pro se, appeals from a final decree of divorce. We construe her numerous

issues on appeal as a complaint that the trial court erred by failing to order the partition-by-sale of

a house that she and her former spouse, John R. Holderman, had purported to convey to

Holderman’s mother prior to the divorce proceeding. We affirm the trial court’s judgment.

BACKGROUND

In December 2013, Gil filed an original petition, alleging the parties had an informal or

common-law marriage before August 2007 and there were no children from the marriage. Gil 04-17-00701-CV

sought a dissolution of the marriage on the grounds of insupportability and cruelty, a division of

community property, temporary orders, and her attorney’s fees. Holderman, who was pro se in the

trial court and is pro se on appeal, generally denied Gil’s allegations.

At a bench trial, the primary issues were whether and when the parties had an informal

marriage and ownership of the houses where Gil and Holderman resided. We refer to the house

Gil lived in as the Bunker Hill House, and the house Holderman lived in as the Madeleine House. 1

The trial court signed a final decree of divorce, granted the divorce on both grounds alleged,

divided the community property, and awarded $1,000 to Gil’s lawyer as attorney’s fees. In the

final decree of divorce, the trial court found the Bunker Hill House was Gil’s separate property

and the Madeleine House belonged to neither Gil nor Holderman.

The trial court also made findings of fact and conclusions of law. The following is a

summary of those findings and conclusions:

Gil and Holderman began their relationship in 2003. The relationship was tumultuous, and they lived together sporadically. Gil purchased the Bunker Hill House before 2003. Gil and Holderman purchased the Madeleine House in 2010, with a loan from Holderman’s mother. The Bunker Hill House, not the Madeleine House, was Gil’s homestead, and Gil no longer lived in the Madeleine House after 2013. In separate deeds executed in 2013, Gil and Holderman conveyed their interests in the Madeleine House to Holderman’s mother. The parties’ informal marriage commenced in February 2012, which is when Holderman gave Gil a wedding ring, Gil started helping Holderman raise his children from a prior marriage, and they started holding themselves out as being married.

Gil filed a motion for new trial on several grounds, including that the trial court erred by finding

the wrong date for the commencement of an informal marriage and by not voiding the deeds to the

Madeleine House. In the motion for new trial, Gil argued the deeds violated restrictions on the

1 Gil’s issues on appeal relate to the Madeleine House.

-2- 04-17-00701-CV

transfer of homestead property and were not validly executed in favor of Holderman’s mother. The

trial court denied the motion for new trial, and Gil timely appealed.

ACCEPTANCE OF BENEFITS

In his appellee’s brief, Holderman asserts without explanation that “applying the

Acceptance of the Benefits Doctrine renders the appeal moot, and must be dismissed for want of

jurisdiction. As a result of the divorce decree, [Gil] received $1000 in attorney’s fees and has

enjoyed the benefits of the decree thereafter.” The acceptance-of-benefits doctrine only “bars an

appeal if the appellant voluntarily accepts the judgment’s benefits and the opposing party is

thereby disadvantaged.” Kramer v. Kastleman, 508 S.W.3d 211, 217 (Tex. 2017). The burden of

proof rests on the party asserting the doctrine, and “[t]he failure to prove all essential elements is

fatal.” Id. Holderman has not provided any evidence or cited to any evidence in the record that Gil

accepted the benefits of the final decree of divorce. This failure of proof is fatal to Holderman’s

assertion of the acceptance-of-benefits doctrine. See id. We therefore conclude this appeal is not

moot, and proceed to address Gil’s issues.

THE MADELEINE HOUSE

Gil raises numerous issues, all of which challenge directly or indirectly the trial court’s

determination that neither Gil nor Holderman owned the Madeleine House. In her issues, Gil posits

that she is entitled to a judgment ordering a partition-by-sale of the Madeleine House, free and

clear of a 2012 deed of trust and two 2013 deeds that Gil and Holderman executed in favor of

Holderman’s mother. Gil further argues she is entitled to an equal distribution of the proceeds from

the sale of the Madeleine House. In support of her position, Gil challenges the 2012 deed of trust

and the 2013 deeds by which she and Holderman purported to convey their interests in the

Madeleine House to Holderman’s mother. We first address Gil’s challenge to the 2012 deed of

trust and then address her challenges to the 2013 deeds. -3- 04-17-00701-CV

A. 2012 Deed of Trust

Gil argues the 2012 deed of trust is void or invalid because she went through bankruptcy

in 2010, she discharged the debt she owed to Holderman’s mother for the loan for the Madeleine

House during a bankruptcy 2010 proceeding, and there was no new consideration for the 2012

deed of trust. “The covenants in a deed of trust . . . are contractual.” Gregory v. Bank of Am., N.A.,

No. 04-16-00435-CV, 2017 WL 2561561, at *3 (Tex. App.—San Antonio June 14, 2017, no pet.)

(mem. op.). To have a valid enforceable contract, consideration is necessary. In re Estate of Childs,

No. 04-15-00623-CV, 2016 WL 3452624, at *3 (Tex. App.—San Antonio June 22, 2016, no pet.)

(mem. op.). “Consideration is a bargained-for exchange of promises or return performance and

consists of benefits and detriments to the contracting parties.” Id. “The party alleging lack of

consideration has the burden to rebut the presumption that a written contract is supported by

consideration.” Id.

Initially, we note that in her pleadings, Gil did not request a declaration from the trial court

that the 2012 deed of trust was void or invalid. See In re Marriage of Day, 497 S.W.3d 87, 90-91

(Tex. App.—Houston [14th Dist.] 2016, pet. denied) (explaining judgments in divorce proceedings

must be supported by the pleadings). And although the evidence shows Gil discharged her debt to

Holderman’s mother in bankruptcy and Holderman’s mother released a lien on the Madeleine

House, both the bankruptcy and the release of the lien occurred in 2010, which is two years before

the 2012 deed of trust was executed. The evidence therefore does not show that the subsequently

executed 2012 deed of trust is void or invalid for lack of consideration.

The 2012 deed of trust was admitted into evidence at the hearing. The deed of trust is a

written document containing an exchange of promises and rights. The deed of trust also recites it

is supported by consideration.

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