Facts:

The case involves Honesto Alvarez, et al. (plaintiffs and appellants) against Pedro K. Espiritu (defendant and appellee). The dispute centers on Lot No. 292 of the Tala Estate, located in Caloocan, Rizal (now Caloocan City). The lot, measuring 2 hectares, 76 ares, and 2 centares, was originally part of the Friar Lands administered under Act No. 1120. On June 29, 1910, the Director of Lands issued Sales Certificate No. 479 in favor of Consolacion Evangelista, who paid P242.04 for the lot, with P60.04 credited for prior rentals. The remaining balance was to be paid in 18 annual installments, starting July 1, 1910. Consolacion married Pedro K. Espiritu on June 13, 1923, and during their marriage, the installments were paid using conjugal funds, completing the payments by 1927. On November 18, 1927, Consolacion executed a deed titled "Assignment of Sales Certificate No. 279," transferring her rights to the lot to Pedro K. Espiritu. Following the approval of this assignm...

Facts:

Background of the Property

• Lot No. 292 of the Tala Estate, located in Caloocan, Rizal (now Caloocan City), originally formed part of the Friar Lands administered under Act No. 1120.
• On June 29, 1910, the Director of Lands issued Sales Certificate No. 479 in favor of Consolacion Evangelista, agreeing to sell the lot for P242.04. P60.04 was credited as paid rentals, and the balance of P182 was to be paid in 18 annual installments.

Marriage and Payment of Installments

• Consolacion Evangelista married Pedro K. Espiritu on June 13, 1923.
• During their marriage, the installments on the lot were paid using conjugal funds, and by 1927, all installments were fully paid.

Assignment of Sales Certificate

• On November 18, 1927, Consolacion Evangelista signed a deed titled "Assignment of Sales Certificate No. 279," assigning her rights and interest in Lot No. 292 to Pedro K. Espiritu.
• The lot was subsequently registered in the names of both spouses, and Transfer Certificate of Title No. 14527 was issued.

Sale and Redemption of the Property

• On February 7, 1946, the spouses sold half of Lot No. 292 to Aniceto Martin under a pacto de retro sale, reserving the right to redeem it within 12 years.
• Consolacion Evangelista died on February 21, 1949, leaving a will that bequeathed her half interest in the remaining unsold portion of Lot No. 292 to Pedro K. Espiritu.
• Pedro K. Espiritu filed for the settlement of his wife's estate, and the court summarily distributed the estate, adjudicating one-fourth of Lot No. 292 to him.

Redemption of the Sold Portion

• Aniceto Martin, the vendee a retro, died, and his children reconveyed their rights to Pedro K. Espiritu on December 4, 1957, stating that he had paid P3,000 to their father before his death.

Legal Dispute

• On January 8, 1959, the plaintiffs (heirs of Consolacion Evangelista) filed an action against Pedro K. Espiritu, claiming that Lot No. 292 was the paraphernal property of Consolacion Evangelista and that they were entitled to three-fourths of the lot.
• Pedro K. Espiritu contended that the lot was conjugal property, with one-half being his share and one-fourth given to him in his wife's will.

Issue:

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Ruling:

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Ratio:

1. Ownership of Friar Lands: Under Act No. 1120, equitable and beneficial title to the land passes to the purchaser upon the issuance of a sales certificate and payment of the first installment. The reservation of title by the government is merely for protection, and the purchaser becomes the owner upon full payment.
2. Paraphernal Property: Lot No. 292 became the paraphernal property of Consolacion Evangelista upon the issuance of the sales certificate in 1910, long before her marriage to Pedro K. Espiritu. Payments made during the marriage using conjugal funds only entitled the conjugal partnership to reimbursement, not ownership.
3. Assignment of Sales Certificate: The assignment of the sales certificate to Pedro K. Espiritu was void under Articles 1334 and 1458 of the Civil Code, which prohibit donations and sales between spouses during marriage.
4. Probate Court's Order: The probate court's order summarily distributing the estate did not conclusively determine the conjugal character of Lot No. 292. Questions of title to property cannot be definitively resolved in probate proceedings unless all heirs agree to submit the issue to the probate court.
5. Redemption of the Property: Pedro K. Espiritu's redemption of the sold portion of Lot No. 292 did not make him the owner of the entire lot. The redemption merely revested ownership in the heirs of Consolacion Evangelista, with Espiritu having a lien for the amount he paid.

Conclusion:

The Supreme Court held that Lot No. 292 was the paraphernal property of Consolacion Evangelista. The case was remanded to the lower court to determine the usufructuary legitime of Pedro K. Espiritu and to settle the amounts advanced by the conjugal partnership, taxes paid, and fruits received by Espiritu.