**Facts:**
Jose Santos, a rice farmer previously married to Josefa Santos with whom he had eight children, entered into an agricultural tenancy dispute resolved in his favor, granting him possession of farmland after his landlord, the Gaspar family, was directed to maintain his tenancy. Post-Josefa’s death, Jose entered a relationship with Maria D. Santos, who had seven children from a previous marriage, and the couple got married. The Gaspar family executed deeds styled as donations but serving as “Disturbance Compensation of Tenant,” granting Jose 6,000 square meters of farmland. Jose disposed of portions of this land through sales and donations, including a questionable donation to Maria.
Jose died intestate, leaving his surviving spouse Maria and his children and grandchildren. A dispute arose over the partition of a 694 sqm portion of the farmland, leading to litigation by his children to include this property in his estate for distribution. Maria resisted, arguing the donated property was conjugal and exclusively hers by virtue of another document Jose executed before his death. The lower courts found issues with the donation to Maria and declared her co-owner of the land with Jose’s children. The Court of Appeals upheld the trial court’s decision but modified it, concluding that the property was community property.
**Issues:**
1. The procedural correctness of Maria’s CA appeal under Rule 44 upon the transitional nature of questions posed.
2. Legality of the donation made by Jose to Maria during their marriage.
3. The nature of Jose’s acquisition of the property from the Gaspar family as gratuitous or onerous (compensation for disturbance as a tenant).
4. Inclusion of the property in the absolute community property of Jose and Maria.
5. Inclusion of Ruben Santos’ children in the partition after proving legitimate filiation.
**Court’s Decision:**
The Supreme Court found that:
1. Maria correctly filed an ordinary appeal under Rule 44 of the Rules to the CA as her appeal raised questions of both law and fact.
2. The donation made by Jose to Maria (Kasulatan ng Pagkakaloob Pala) was null and void per Article 87 of the Family Code, which prohibits gratuitous transfers between spouses.
3. The CA was mistaken in finding that the deed of donation constituted a gratuitous transfer from the Gaspar family to Jose. The transfer was by onerous title, being for disturbance compensation due to the cessation of Jose’s tenancy.
4. The property was part of the absolute community property, and upon Jose’s death, one-half automatically belonged to Maria.
5. The Supreme Court ruled that Bettina and Reuben Joseph, the children of Ruben Santos, should be included in the partition, as there was consensus among heir recognizing them as grandchildren of Jose.
**Doctrine:**
– Donations between spouses during marriage are prohibited under Article 87 of the Family Code.
– Property transferred by onerous title during marriage forms part of the absolute community property of the spouses unless excluded under Article 93 of the Family Code.
– In succession, the surviving spouse is at parity with the children of the deceased in the distribution of the estate.
**Historical Background:**
The case reflects a confluence of family property relations, agrarian tenancy rights, and inheritance laws in the Philippines. Property acquired as disturbance compensation for tenancy has been traditionally significant due to the Philippines’ agrarian background, where landlord-tenant disputes were, and continue to be, prevalent. The ruling on disturbance compensation addresses these historical agrarian concerns while balancing modern family law principles, as embodied in the Family Code of the Philippines, which took effect in August 1988. The Family Code introduced provisions that reformed property relations between spouses, deeming donations between them void during marriage except under certain conditions. The case underscores the intricacies of such intersecting legal domains at the intersection of family relations, property acquisition, and community property principles, influenced by the historical backdrop of agrarian reform and family law evolution in the Philippines.
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