G.R. No. 173002 - Bautista vs. Ugst

In special proceedings before the Court of First Instance of Manila, Ramon Joaquin, the duly appointed administrator of the intestate estate of Joaquin Navarro and Angela Joaquin, returned an amended inventory and appraisal of all real and personal properties under his possession or knowledge.
The inventory was prepared pursuant to section 1(a) of Rule 82 and section 1 of Rule 84.
Among the properties inventoried is a parcel of land located on San Marcelino Street, district of Ermita, Manila, with an area of 1,553.20 sq. m., originally included under the heading “paraphernal property of Angela Joaquin.”

Antonio C. Navarro, a child of the late Joaquin Navarro by another marriage, objected to:

The classification of four real properties (including the parcel of land designated as No. 4) as paraphernal property of Angela Joaquin.
The assertion that these properties, especially the contested parcel of land, belonged solely to Angela Joaquin when, by presumption, they were acquired during coverture and thus should be deemed conjugal.

The inclusion of values attributed to jewelry, gold coins, and personal property disposed of during the marriage.
The correctness of the appraised value of the inventoried real estate.

On 18 February 1909, Joaquin Navarro and Angela Joaquin executed capitulaciones matrimoniales (an ante-nuptial agreement) before witnesses and a notary public.

This agreement itemized certain properties (real estate, cash, jewelry, and furniture) as belonging exclusively to Angela Joaquin and reserved for her administration.

That the first three lots listed under Angela Joaquin’s paraphernal properties are among those described in the capitulaciones matrimoniales.
However, the parcel of land under inventory listing No. 4 is not included in the capitulaciones matrimoniales, even though its original certificate of title was issued in the name “Angela Joaquin, the wife of Joaquin Navarro.”

The real properties corresponding to lots known by their titles (e.g., lot No. 6, block No. 1832; lot No. 9, block No. 1846; and lot No. 6, block No. 3001) were indeed Angela Joaquin’s paraphernal properties.
The parcel of land listed as No. 4 was acquired during the marriage and, therefore, was presumed to be conjugal property despite being registered in the wife’s name.

The exclusion of the jewelry, gold coins, and personal property disposed of during the marriage from the inventory since these items were not found among the remaining assets at the time of death.
That the administrator file an amended inventory with the Court and furnish a copy to the Collector of Internal Revenue for proper appraisal.

After a motion for reconsideration by the administrator was denied by the probate court, the administrator appealed.
The Court of Appeals certified the appeal to the Supreme Court, as the issues raised were deemed purely legal in nature.
The case involves a dispute among heirs of the deceased spouses, particularly between Ramon Joaquin (administrator and son of Angela Joaquin) and Antonio C. Navarro (legitimate child of Joaquin Navarro from another marriage).

Whether the parcel of land labeled as No. 4 in the amended inventory should be classified as paraphernal property of Angela Joaquin or as conjugal property acquired during the marriage.

Whether the value of the jewelry, gold coins, and personal property, which were sold or otherwise disposed of during the marriage, should be included in the inventory, considering that they were not found among the properties at the time of death.

Whether the registration of the parcel of land in Angela Joaquin’s name—as evidenced on the certificate of title—compels its classification as paraphernal property, notwithstanding the presumption that property acquired during coverture is conjugal.