Case Digest (G.R. No. 179010) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Soledad L. Lavadia vs. Heirs of Juan Luces Luna, G.R. No. 171914, decided July 23, 2014, petitioner Soledad L. Lavadia, the second spouse of the late Atty. Juan Luces Luna, sought recognition of her co-ownership in a condominium unit and law books acquired during her purported marriage to Luna. Luna had first married Eugenia Zaballero in a civil ceremony on September 10, 1947 and a church ceremony on September 12, 1948, and they bore seven children. In February 1966, the couple agreed to separate and, on November 12, 1975, executed an “Agreement for Separation and Property Settlement” to dissolve and liquidate their conjugal partnership. On January 12, 1976, Luna obtained a divorce decree in the Dominican Republic and married Lavadia the same day. Back in Makati City, Luna organized new law firms, acquiring on installment basis in 1978 a 517.52-sqm condominium unit for P1,449,056.00 to serve as office, and later law books. The Deed of Absolute Sale and subsequent titles liste Case Digest (G.R. No. 179010) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Marital History of Atty. Juan Luces Luna
- First marriage to Eugenia Zaballero-Luna: civil ceremony (Sept. 10, 1947), church solemnization (Sept. 12, 1948); seven (7) children born of the union.
- Separation and foreign divorce: agreed to live apart (Feb. 1966); executed “Agreement for Separation and Property Settlement” (Nov. 12, 1975); obtained Dominican Republic divorce decree (Jan. 12, 1976).
- Second marriage to Soledad L. Lavadia: contracted in Sto. Domingo, Dominican Republic (Jan. 12, 1976); cohabited in the Philippines until Luna’s death (July 12, 1997).
- Acquisition of Condominium Unit and Law Practice
- Formation of law firm LUPSICON (1977); Feb. 14, 1978 purchase of 6th floor, Kalaw-Ledesma Condominium Project, Makati (517.52 sqm; P1,449,056.00, 36-month installment).
- Deed of Absolute Sale executed (July 15, 1983); CCT No. 4779 (Aug. 10, 1983): Luna (46/100), Ongkiko (25/100), Puruganan (17/100), Sison (12/100).
- Sale of shares and reissuance of CCT No. 21761 (Feb. 7, 1992): Luna (38/100), Ongkiko (50/100), Sison (12/100).
- Dissolution of LUPSICON (1992); condominium partition fixed Luna’s interest at 25/100; subsequent law firm with De la Cruz until Luna’s death.
- Post-Death Possession and Litigation
- Luna’s son Gregorio Z. Luna took over 25/100 share and law books; leased share to Atty. De la Cruz.
- Soledad’s complaint (Sept. 10, 1999, RTC Makati Branch 138, Civil Case No. 99-1644): claimed 34/100 pro indiviso share (25/100 of unit + law books), partition, accounting, receiver, attorney’s fees.
- Decisions Below
- RTC (Aug. 27, 2001): held 24/100 share acquired by Luna’s sole industry; Soledad had no right to condominium; awarded law books to Soledad; changed Luna’s spouse designation on title to Eugenia.
- CA (Nov. 11, 2005, modified): declared 25/100 share and law books belonged to heirs of Luna and Eugenia; Soledad had no ownership; confirmed title change to reflect first marriage.
Issues:
- Validity and effect of the Dominican Republic divorce decree and separation agreement
- Whether foreign divorce and court-approved separation dissolved Luna’s conjugal partnership with Eugenia.
- Whether Philippine law must recognize such foreign decree and agreement.
- Validity of Luna’s second marriage to Soledad and its effect on property rights
- Whether the second marriage was void ab initio for bigamy.
- The legal regime governing properties acquired during a void marriage.
- Soledad’s co-ownership claim over the condominium share and law books
- Whether Soledad proved actual contribution to acquisition under Article 144, Civil Code and Article 148, Family Code.
- Sufficiency of evidence (checks, cash, thank-you note) to establish co-ownership.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)