G.R. No. L-16991 - Laperal, Jr. vs. Katigbak

The dispute centers on the property covered by Transfer Certificate of Title (TCT) No. 57626, located in the City of Manila.
The trial court initially declared the property as the separate or paraphernal property of defendant-appellee Evelina Kalaw.
Plaintiffs-appellants, the Laperals (spouses), contested this finding, claiming that the property—along with its improvements and income—forms part of the conjugal assets jointly owned by Evelina Kalaw and Ramon Katigbak.

The litigation is a sequel to an earlier complaint instituted by the Laperals against Katigbak and Kalaw in August 1950 (Civil Case No. 11767).

In that prior case, the Laperals sought the recovery of P14,000 evidenced by promissory notes executed by Katigbak and the return or equivalent monetary compensation for jewelry valued at P97,500.
On November 1, 1950, following a confession of judgment by Katigbak, the trial court ruled in favor of the Laperals by ordering Katigbak to pay the sum and return the jewelry (or its equivalent).

Shortly after, in Civil Case No. 12860, Evelina Kalaw filed a complaint for "judicial separation of property and separate administration" against her husband, Ramon Katigbak.

Prior to trial, both parties submitted a stipulation of facts which led the trial court to grant the prayer for separation of property.

In February 1955, the Laperals filed yet another complaint (Civil Case No. 25235) seeking:

Annulment of the proceedings for the judicial separation of property.
Enforcement of the judgment on the fruits of Kalaw’s paraphernal property.
A declaration that the property covered by TCT No. 57626 is conjugal property of Katigbak and Kalaw.

The dismissal was appealed by the Laperals, leading to the present case reviewed by the Supreme Court.

It is established that the spouses were married in 1938 and neither brought any property into the marriage.
The property in question was purchased and registered in the name of Evelina Kalaw-Katigbak on December 6, 1939, only two years after their marriage.

At the time of acquisition, Ramon Katigbak’s income was limited to a monthly salary of P200 as an Assistant Attorney at the Bank of the Philippine Islands, implying that he could not have singly afforded a property of substantial value.

Evelina Kalaw testified that the property was purchased with funds furnished by her mother, Pura Villanueva, who routinely provided money for her children to buy properties in their own names.
The deed was executed in favor of the wife alone, following a practice established by her family.

A key piece of evidence was the manifestation made by Ramon Katigbak in 1939, wherein he stated that he had no interest in the property, signing the document merely to assist his wife.
This testimony, coupled with the financial facts and the registration of the title in the wife’s name, formed the basis for the trial court’s conclusion.

The trial court’s findings were compared to established cases such as Gasiano vs. Samaniego and Coingco vs. Flores.

In these cases, similar evidentiary circumstances (title in the wife’s name, separate funds from a parent) were accepted as sufficient to rebut the legal presumption of conjugal ownership for properties acquired during the marriage.

Whether the legal presumption that properties acquired during coverture (marriage) are conjugal may be rebutted by evidence showing that:

The property title is in the name of the wife only;
The property was purchased with funds not derived from the conjugal common stock but from the separate property (in this case, funds provided by the wife’s mother); and
The husband, who had a limited income, manifested no interest in the property.

Whether these facts are sufficient to classify the property covered by TCT No. 57626 as paraphernal, despite its acquisition during the marriage.