Case Digest (A.C. No. 5299, 157053) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Mercedes Calimlim-Canullas vs. Hon. Willelmo Fortun and Corazon Daguines (G.R. No. L-57499, decided June 22, 1984 under the 1973 Constitution and the Civil Code of the Philippines), petitioner Mercedes Calimlim-Canullas and her husband Fernando Canullas were married on December 19, 1962, and had five children. They lived in a modest dwelling erected on an 891-square-meter parcel at Bacabac, Bugallon, Pangasinan, which Fernando inherited upon his father’s death in 1965. In 1978 Fernando deserted his family and cohabited with private respondent Corazon Daguines. On April 15, 1980, Fernando executed a deed of sale conveying the entire lot together with the house—described as “inherited by me from my deceased parents”—to Daguines for ₱2,000. Unable to take possession, Daguines filed on June 19, 1980 a complaint for quieting of title and damages against Mercedes before the Court of First Instance of Pangasinan, Branch I, claiming ownership of the land and improvements. Mercedes re Case Digest (A.C. No. 5299, 157053) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Marriage
- Mercedes Calimlim-Canullas (petitioner) and Fernando Canullas married on December 19, 1962; they had five children.
- They resided in a small house on a residential lot (≈ 891 m²) in Bacabac, Bugallon, Pangasinan, which Fernando inherited in 1965.
- Abandonment and Criminal Conviction
- In 1978 Fernando abandoned Mercedes and their children and cohabited with Corazon Daguines (private respondent).
- On October 27, 1981, Fernando and Daguines were convicted of concubinage; the judgment became final.
- Sale of Property and Civil Litigation
- On April 15, 1980, Fernando sold the lot and house to Daguines for ₱2,000; the deed described the house as “also inherited by me from my deceased parents.”
- Daguines sued Mercedes on June 19, 1980 for quieting of title and damages; Mercedes countered that the house, coconut trees, and other improvements were conjugal property built with conjugal funds and without her consent.
- Trial Court Dispositions
- October 6, 1980 Decision: Declared Daguines owner of the land and one-half of the house.
- November 27, 1980 Resolution (on reconsideration): Amended disposition to declare Daguines owner of the land and ten coconut trees, but annulled the sale of the conjugal house, three coconut trees, and other improvements.
Issues:
- Whether buildings erected during marriage on one spouse’s exclusive land ipso facto convert the land into conjugal property.
- Whether the sale of the lot together with the house and improvements was valid under the circumstances (sale by husband to concubine, without spousal consent).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)