G.R. No. L-2090 - Facturan vs. Sabanal

The case involves petitioners Tomasa Facturan et al. and respondents Raymunda Sabanal, the heirs of Francisco Sevilla, Benedicto Libcon, Bernabela Facturan, and Eugenio Sevilla.
The dispute centers on the ownership status of a parcel of land, specifically whether it is conjugal property acquired during marriage or the exclusive, private property of the late Alfonso Facturan.

The record includes a complete transcription of stenographic notes showing that exceptions were expressly taken from the trial court’s orders striking out the corroborative testimonies of witnesses for the appellant.
A key piece of evidence is the testimony of the widow, who stated that the property in question was acquired during the marriage, which is sufficient to create a legal presumption of the property being conjugal.
Other corroborative forms of evidence included exhibits (e.g., Exhibits E and E-1) and additional oral testimonies supporting the fact that the sale contract for the property was executed during the marriage.
The evidence regarding the property also brought into question whether the purchase occurred while Alfonso Facturan was married, with testimonies conflicting on whether he acquired the property before or during the marriage.

The lower court excluded the oral testimonies, particularly those of Raymunda Sabanal, aimed at proving the purchase of the property during the marriage.
Exceptions to this exclusion were raised and recorded, and these issues were carried on appeal.
The petitioners argued that even if the corroborative evidence were disregarded, the widow’s testimony alone sufficed to legally presume that the property was conjugal.
A legal contention arose concerning the applicability of the Statute of Frauds; specifically, whether it applied to the oral contract of sale at issue, given that the sale was an executed contract and not merely executory.
The Court of Appeals concluded that the Statute of Frauds did not apply in this matter and that the exclusion of oral evidence by the trial court was erroneous yet inconsequential in light of the overwhelming evidence establishing conjugal ownership.

Whether the Court of Appeals erred in reversing the trial court’s exclusion of the corroborative oral testimonies regarding the purchase of the disputed land.
Whether the oral testimonies, including the critical testimony of the widow, should have been admitted as evidence to support the presumption that the property was acquired during marriage and is thus conjugal.
Whether the Statute of Frauds, which generally applies to executory contracts, is applicable in this instance involving an executed sale contract, and hence, whether its invocation to exclude the oral testimony was justified.