Case Digest (G.R. No. L-18833)
Facts:
- The case Alvarez v. Espiritu (G.R. No. L-18833) was decided by the Supreme Court of the Philippines on August 14, 1965.
- Plaintiffs-appellants Honesto Alvarez and others disputed the ownership of Lot No. 292 of the Tala Estate, claimed by defendant-appellee Pedro K. Espiritu.
- The lot was part of the Friar Lands managed under Act No. 1120.
- Consolacion Evangelista, Pedro's deceased wife, acquired the lot on June 29, 1910, through Sales Certificate No. 479 for P242.04, with the first installment due on July 1, 1910.
- Consolacion married Pedro on June 13, 1923, and they used conjugal funds to pay the remaining installments, completing payment in 1927.
- On November 18, 1927, Consolacion executed a deed of assignment transferring her interest in the lot to herself and Pedro, which was registered in their names.
- After Consolacion's death on February 21, 1949, Pedro sought a summary settlement of her estate, claiming the lot as conjugal property.
- The lower court ruled in favor of Pedro, declaring him the owner of the entire lot, leading to an appeal from the plaintiffs.
Issue:
- (Unlock)
Ruling:
- The Supreme Court determined that Lot No. 292 was the paraphernal property of Consolacion Evangelista, not the conjugal property of Consolacion and Pedro K. Espiritu.
- The Court reversed the lower court's decision, stating that the conjugal partnership was entitled only to reimbursement for expenses paid with conjugal funds.
- The assignment of the sales certifi...(Unlock)
Ratio:
- The Supreme Court highlighted that properties acquired by a woman before marriage remain her paraphernal properties, even if some payments are made with conjugal funds during marriage.
- The Court referenced Director of Lands v. Rizal, asserting that equitable title passes to the purchaser upon issuance of the sales certificate, with the government retaining no ownership rights beyond protecting its interests.
- The assignment of the sales certificate was void as it constituted a prohibited transaction between...continue reading
Case Digest (G.R. No. L-18833)
Facts:
The case of Alvarez v. Espiritu (G.R. No. L-18833) was decided by the Supreme Court of the Philippines on August 14, 1965. The plaintiffs-appellants, Honesto Alvarez and others, contested the ownership of Lot No. 292 of the Tala Estate, which was claimed by the defendant-appellee, Pedro K. Espiritu. This lot, situated in Caloocan, Rizal, was originally part of the Friar Lands administered under Act No. 1120. The lot was acquired by Consolacion Evangelista, the late wife of Pedro K. Espiritu, on June 29, 1910, through Sales Certificate No. 479, for a total price of P242.04, with the first installment due on July 1, 1910. Consolacion married Pedro on June 13, 1923, and during their marriage, they paid the remaining installments using conjugal funds, completing the payment in 1927. On November 18, 1927, Consolacion executed a deed of assignment transferring her interest in the lot to herself and Pedro, which was subsequently registered in their names. After Consolacion's death on February 21, 1949, Pedro filed for the summary settlement of her estate, claiming the lot as conjugal property. The lower court initially ruled in favor of Pedro, declaring him the owner of the entire lot, which led to the appeal by the plaintiffs who contended that the lot was Consolacion's paraphernal property.
Issue:
- Was Lot No. 292 the paraphernal property of Consolacion Evangelista or the conjugal property of Consolacion Evangelista and Pedro K. ...