G.R. No. 221874 - Dultra Vda. de Canada vs. Baclot

Agrifina Dultra vda. de Canada (petitioner) was one of the legally married Spouses Canada, married on September 4, 1937, in Cagayan de Oro City.
Fifteen years into the marriage, the Spouses Canada separated when Sancho (the husband) left the conjugal abode in 1952.
Following the separation, Sancho entered into a common-law relationship with Cresencia Baclot, with whom he had seven children (Sanchito, Roberto, Alfreda, Renato, Ronaldo, Ronel, and Rizalino Canada).

After Sancho’s death intestate on February 10, 1973, petitioner, acting as the Administrator of his intestate estate, filed a complaint for recovery of ownership and possession of various properties, along with accounting and damages.
The subject properties include:

Commercial land acquired in 1957 covered by TCT No. T-2190.
Several parcels of cocoland with improvements located in Cabinti-an, Kitobao, and Mingcawayan, Misamis Oriental (with corresponding tax declarations).
Agricultural lands, as well as residential lots located in Talisay, Gingoog City.

Petitioner amended her complaint twice to include her children and additional properties.

The RTC of Gingoog City, Misamis Oriental, Branch 27 rendered a decision on March 13, 2012, favoring petitioner.
The RTC’s decision was based primarily on the testimony of Estrella Canada Saguit, who is a daughter from the Spouses Canada.
The RTC ordered the delivery and restoration of possession of the subject properties to the intestate estate of Sancho, which would benefit petitioner and his children.

Respondents (the heirs of Cresencia and Sanchito among others) appealed the RTC decision, disputing petitioner’s claim by asserting that the properties were registered in Cresencia’s name.
The CA, in its decision dated June 17, 2015, reversed the RTC ruling.
The CA clarified that:

Although there were various properties involved, the subject properties when properly identified amounted to nine, not eleven.
There was insufficient evidence to prove that Sancho contributed jointly in acquiring the properties.
With the properties registered in Cresencia’s name (except one property registered in the name of Sanchito), petitioner’s claim failed to establish a joint contribution.

Petitioner contended that due to Cresencia’s limited financial means as a dressmaker, it was implausible for her to have acquired the subject properties on her own.
Respondents maintained that, without proof of Sancho’s contribution, the properties remain solely in Cresencia’s name.
The dispute centered on whether cohabitation in this instance could give rise to a presumption of joint contribution and co-ownership under the applicable law.

The issue of whether the property acquired during the cohabitation of Sancho and Cresencia falls under the ambit of co-ownership was pivotal.
The determination of co-ownership was to be guided primarily by Article 148 of the Family Code, rather than Article 144 of the Civil Code, considering that Sancho was still married to the petitioner when cohabiting with Cresencia.
The CA emphasized the need for actual proof of joint contribution to invoke co-ownership, as mere registration or assumptions based on financial capability are insufficient.

Whether the petitioner established that the subject properties were acquired through the actual joint contributions of Sancho during his cohabitation with Cresencia.

The determination hinges on whether Sancho’s financial or material input in acquiring the properties was clearly demonstrated.
Whether Cresencia’s registration of title, on its face, precludes a claim of co-ownership by petitioner and Sancho’s legal heirs.

Whether the applicability of Article 148 of the Family Code is proper in characterizing the property regime during Sancho’s cohabitation with Cresencia.

The legal effect of Sancho’s incapacity to enter into a valid marriage with Cresencia while still married to the petitioner.
Whether joint contributions under cohabitation can be presumed absent concrete evidence establishing such contributions.

Whether the evidence provided by petitioner sufficiently rebutted the presumption of separate ownership suggested by the registration of the subject properties in Cresencia’s (and Sanchito’s) name.