Facts:

• In June 2002, Fatima B. Gonzales-Asdala and her husband, Wynne B. Asdala, applied for a PHP1,500,000.00 loan from Metropolitan Bank and Trust Company (Metrobank) to renovate their house in Quezon City.
• The property was covered by Transfer Certificate of Title No. 377659 and registered in the name of "Wynne B. Asdala, married to Fatima G. Asdala."
• On July 22, 2002, the couple executed three Promissory Notes in favor of Metrobank, which included a clause for procuring a Mortgage Redemption Insurance (MRI) if required by the bank.
• They also constituted a Real Estate Mortgage on the property as security for the loan.
• Metrobank informed them on November 26, 2002, that the first annual MRI premium of PHP6,884.10 was due on July 24, 2003.
• Over the years, the couple was billed for MRI premiums, but no receipts or policies were issued, with only a debit memo as proof of payment.
• Wynne died on March 24, 2008, and Fatima requested the discharge of the mortgage, claiming the MRI premiums were paid by her husband.
• Metrobank denied the request, stating the MRI was issued solely in Fatima's name and the premiums were debited from her savings account.
• Fatima filed a Complaint for Specific Performance, Injunction, and Damages with a Prayer for Temporary Restraining Order and Preliminary Injunction against Metrobank.
• The Regional Trial Court (RTC) dismissed her complaint, ruling that the property was presumed conjugal and that Fatima, as a co-mortgagor, could secure an MRI on her life alone.
• The Court of Appeals (CA) affirmed the RTC's decision.
• Fatima then filed a Petition for Review on Certiorari with the Supreme Court.

Issue:

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Ruling:

• The Supreme Court denied the Petition for Review on Certiorari.
• It affirmed the January 3, 2020 Decision and the Mar...(Unlock)

Ratio:

• The Supreme Court held that the parcel of land subject to the real estate mortgage is conjugal. The property was acquired during the marriage, evidenced by the Transfer Certificate of Title issued in 1988, seven years after the couple's marriage in 1981. The petitioner failed to present any other evidence to prove the property was acquired before the marriage.
• Under the Civil Code, properties acquired during the marriage are presumed conjugal unless proven otherwise with strong, clear, and convincing evidence, which the petitioner failed to provide.
• Regarding the MRI, the insurance was issued solely in the petitioner's name, and the premiums were paid from her savings account. The documents for the MRI were signed by the petitioner alone, and the Certificate of Group Lif...continue reading