Case Digest (G.R. No. 236659) Core Legal Reasoning Model
Facts:
The case presented involves a dispute between Bernard B. Benasa (the petitioner) and Presentacion R. Mahor (the respondent). Benasa initiated a legal action on January 26, 2012, seeking accounting, inventory, and reconveyance of real properties along with damages. This arose from a relationship that began in 1974, while Mahor was still married to Pablo Mahor. Benasa, who remained single, became a seafarer and regularly sent financial remittances to Mahor during their association. He contended that these remittances were used by Mahor to purchase multiple properties in the Philippines, specifically lots in Quezon City, Tagaytay City, and Baliuag, Bulacan, which were registered solely in Mahor's name. Although he instructed Mahor to register these properties in his name, she failed to comply.
Problems escalated when Benasa, after retiring in 1999, demanded a complete accounting of the money and properties that he had entrusted to Mahor, which she did not provide. Their relati
Case Digest (G.R. No. 236659) Expanded Legal Reasoning Model
Facts:
- Background of the Parties
- Petitioner Bernard B. Benasa (Benasa) and respondent Presentacion R. Mahor (Mahor) were childhood sweethearts.
- Mahor married Pablo Mahor (Pablo), while Benasa remained single and worked as a seafarer.
- Adulterous Relationship and Financial Remittances
- In 1974, while Mahor’s marriage to Pablo was still subsisting, Benasa and Mahor rekindled their relationship and engaged in an adulterous affair.
- Benasa regularly sent his salaries and benefits to Mahor in monthly allotments, which she allegedly used to purchase several real properties in Quezon City, Tagaytay City, and Baliuag, Bulacan.
- The properties were registered solely in Mahor’s name, contrary to Benasa’s instructions to register them under his name.
- Retirement and Demand for Accounting
- Upon Benasa’s retirement in 1999, he requested Mahor to account for the cash remittances and properties purchased during their cohabitation.
- Mahor refused, leading to their separation.
- In 2009, Benasa sent a formal demand letter to Mahor, but she still did not comply.
- Filing of the Petition
- Benasa filed a Petition for Accounting, Inventory, and Reconveyance of Real Properties with Damages before the Regional Trial Court (RTC).
- He claimed co-ownership of the properties under Articles 147 or 148 of the Family Code, arguing that the properties were acquired using his remittances.
- Evidence Presented by Benasa
- Benasa presented allotment slips, passbooks, and letters from Mahor acknowledging receipt of his remittances.
- He also submitted photographs of the properties and personal items, as well as love letters exchanged between them.
- Benasa’s brother testified that Benasa and Mahor lived together as husband and wife.
- Mahor’s Default and RTC Decision
- Mahor was declared in default for failing to file an Answer.
- The RTC dismissed Benasa’s petition, ruling that the evidence was insufficient to prove co-ownership under Articles 147 or 148 of the Family Code.
- The RTC held that the relationship was not a legal cohabitation but a mere love affair.
- Appeal to the Court of Appeals (CA)
- The CA affirmed the RTC’s decision, stating that Benasa and Mahor did not cohabit as husband and wife.
- The CA also ruled that the properties were presumed conjugal since they were acquired during Mahor’s marriage to Pablo.
Issues:
- Whether the CA erred in ruling that Benasa and Mahor did not cohabit as husband and wife under Article 148 of the Family Code.
- Whether Benasa is entitled to a co-ownership share in the properties acquired during their relationship.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)