Case Summary (G.R. No. 84433)
Background and Factual Summary
The relationship between Benasa and Mahor, which began in 1974, evolved into an adulterous affair while Mahor was still married to Pablo Mahor. Benasa asserted that he sent substantial financial support to Mahor during their relationship, which allegedly enabled her to purchase several real properties in the Philippines, including properties registered only in her name despite his instructions to register them under his name. After Benasa's retirement in 1999, he sought an inventory and accounting of the properties acquired during their relationship, but Mahor failed to comply. Following a decade without resolution, Benasa formally filed his petition in 2012.
Legal Framework
Benasa based his claims on Articles 147 and 148 of the Family Code. Article 148 governs the property relations of couples in adulterous relationships, indicating that properties acquired by cohabiting parties shall be owned in common according to their respective contributions.
Proceedings in the RTC
The RTC dismissed Benasa's petition, concluding that he failed to prove a legal basis for co-ownership according to the Family Code. The court characterized the relationship as a simple love affair, not meeting the legal definition of cohabitation, which requires living together as husband and wife. The RTC also deemed Benasa's evidence insufficient, finding that his remittances did not carry instructions indicating Mahor was to hold them in trust for him. Furthermore, the court maintained that the properties acquired during Mahor's marriage belonged to her and her legal husband, creating a presumption of ownership that was not overcome by Benasa's arguments.
Court of Appeals' Decision
Benasa's appeal to the Court of Appeals (CA) was also dismissed. The CA concurred with the RTC's assessment that, given the properties were acquired during Mahor's marriage, they were presumed to be conjugal property. The CA reaffirmed the finding that Benasa had not sufficiently proven the nature of their relationship as cohabitation, given that he had spent significant periods working abroad. Thus, the CA echoed the lower court's dismissal of claims regarding the ownership of properties and supported the notion that the remittances did not equate to the financial support characteristic of marital relations.
Supreme Court's Ruling
The Supreme Court granted Benasa's petition, asserting that the legal relationship between the parties was governed by Article 148 of the Family Code concerning their cohabitation. The Court emphasized that despite the irregular nature of Benasa's employment as a seafarer, significant evidence indicated that he and Mahor had established a long-term cohabitation relationship. The Court noted Benasa's substantial remittances and his actions and intent to maintain the relationship, as established through documentation of financial transfers and affectionate correspondence.
Findings Regarding Property Ownership
The Court ruled that the properties acquired during their cohabitation must be considered co-owned, attributing to Benasa the right to an accounting and reconveyance of properties he contributed towards. The registration of the properties solely under Mahor’s name was not conclusive evidence of ownership, thus allowing for t
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Case Background
- Petitioner Bernard B. Benasa filed a Petition for Review on Certiorari against Presentacion R. Mahor.
- The case originated from a Petition for Accounting, Inventory, and Reconveyance of Real Properties with Damages filed by Benasa in the Regional Trial Court (RTC) of Quezon City.
- The RTC dismissed Benasa's petition, which was subsequently upheld by the Court of Appeals (CA).
Relationship History
- Benasa and Mahor were childhood sweethearts; Mahor was married to another man, Pablo Mahor, during their relationship.
- Their romantic involvement rekindled in 1974, leading to an adulterous relationship.
- Benasa, a seafarer, regularly remitted money to Mahor during their time together.
Financial Contributions and Property Claims
- Benasa claimed that the money he sent, totaling US$585,755.89 and P200,927.00, was used by Mahor to purchase several properties in the Philippines.
- The properties in dispute were registered solely in Mahor's name, contrary to Benasa's instructions to register them under his name.
Attempts for Accounting and Inventory
- After retiring in 1999, Benasa requested an inventory and accounting of his remittances and the properties bought with that money.
- Mahor's failure to comply with this request led to a breakdown in their relationship.
Legal Proceedings
- Benasa sought a complete accounting