**Facts:**
In August 1950, the Laperals filed a civil case (Civil Case No. 11767) against Ramon Katigbak, involving P14,000 in promissory notes and jewelry valued at P97,500, supposedly delivered to Katigbak for commission-based sale. The court ruled in favor of the Laperals when Katigbak confessed judgment, ordering him to settle the debt and return the jewelry or its value with interest.
Following this, in December 1950, Evelina Kalaw, Katigbak’s wife, filed for judicial separation of property (Civil Case No. 12860), resulting in a mutual agreement that was accepted by the court.
On February 1, 1955, the Laperals initiated another case against Kalaw and Katigbak (Civil Case No. 25235). They sought to annul the separation proceedings, enforce judgment from Civil Case No. 11767 against Kalaw’s property income, and claim that the property under TCT No. 57626 was conjugal. The trial court dismissed the complaint, prompting an appeal to the Supreme Court.
The Supreme Court (G.R. No. L-11418, December 27, 1958) remanded the case to the trial court, directing an examination of whether the disputed property was conjugal or separate. The trial court found the property to be paraphernal, leading to this appeal by the Laperals.
**Issues:**
1. Whether the presumption under Article 160 of the Civil Code that properties acquired during marriage are conjugal was adequately rebutted.
2. Whether the property under TCT No. 57626, acquired during marriage, is Evelina Kalaw’s paraphernal property.
**Court’s Decision:**
The Supreme Court focused on whether the presumption of conjugal property established under Article 160 of the Civil Code was rebutted. The Court affirmed the trial court’s ruling, finding the evidence sufficient to show the property was paraphernal.
– **Rebuttal of Conjugal Presumption:** The court examined evidence that demonstrated Evelina Kalaw’s mother bought the property and placed it in Kalaw’s name, consistent with the family’s tradition of registering properties in children’s names.
– **Consideration of Evidence:** Despite the presumption under Article 160 that properties acquired during marriage are conjugal, Kalaw presented evidence that the purchase funds originated from her mother, supporting her claim of ownership. This evidence was found compelling since Katigbak, with a meager salary, could not financially justify his purchasing capability.
– **Cited Precedents:** The Court’s analysis aligned with earlier decisions (Casiano vs. Samaniego and Coingco vs. Flores), where deeds in the wife’s name and financial inability of the husband reinforced the conclusion that the presumption of conjugal ownership was effectively rebutted.
**Doctrine:**
The doctrine reiterated is that the presumption of conjugal property under Article 160 of the Civil Code is rebuttable, and ownership can be disproven with substantial counterevidence demonstrating the separate acquisition of the property by one spouse.
**Class Notes:**
– **Article 160, Civil Code:** Creates a rebuttable presumption in favor of conjugal ownership for properties acquired during marriage.
– **Paraphernal Property:** Identified through substantial evidence demonstrating acquisition or funding separately from conjugal resources.
**Historical Background:**
During the Philippines’ post-war period, issues of asset distribution often involved substantial property disputes, reflecting familial strategies like setting property titles in descendants’ names. This case underscores the legal complexities arising from such familial financial planning and its resulting disputes within Philippine legal jurisprudence.
Leave a Reply