Case Summary (G.R. No. 221874)
Relevant Antecedents
Agrifina and Sancho Canada were legally married on September 4, 1937, in Cagayan de Oro City and had six children. After separating in 1952, Sancho began cohabiting with Cresencia, with whom he fathered seven more children. The conflict intensified after Sancho's intestate death on February 10, 1973. Agrifina, as the appointed administrator of his estate, filed a complaint against Cresencia in 1994 to recover Sancho's properties.
Nature of the Complaint
Agrifina's initial complaint sought recovery of six parcels of land allegedly owned by Sancho. Over time, she amended her complaint to include additional properties, alleging that all were rightfully part of Sancho's estate. Cresencia contested this claim, asserting her ownership based on her own efforts and industry. After Cresencia's death in 2004, her heirs continued to defend her rights to the properties.
Lower Court Rulings
On March 13, 2012, the Regional Trial Court ruled in favor of Agrifina, ordering the delivery of the properties to her and Sancho's children. The court based its decision on the testimony of one of Sancho's daughters, concluding that insufficient evidence existed to prove Cresencia could own the properties in question. The court also ordered an accounting of property fruits and awarded attorney’s fees.
Court of Appeals Decision
The case was appealed, leading to a reversal by the Court of Appeals on June 17, 2015. The Appeals Court found that the evidence failed to establish shared ownership, as the properties were primarily registered in Cresencia’s name. It highlighted the need for actual joint contributions to ownership under Article 148 of the Family Code, as the relationship between Sancho and Cresencia was deemed governed by that provision due to Sancho’s valid marriage to Agrifina.
Legal Framework
The case's legal considerations pivot on the applicability of Article 148 of the Family Code, which stipulates that properties acquired during cohabitation must be owned in common only through actual joint contributions. The Appeals Court emphasized the absence of substantive evidence demonstrating that Sancho contributed to the acquisition of the properties, ultimately leading to the dismissal of Agrifina's claim for lack of merit.
Burden of Proof
The ruling underscored the principle that the burden of proof rests upon the party asserting ownership. Both the Regional T
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Case Background
- The case involves a petition for review on certiorari filed by Agrifina Dultra Vda. De Canada (petitioner) against Cresencia Baclot and her heirs (respondents).
- The petition was prompted by the Court of Appeals-Cagayan de Oro City’s decision dated June 17, 2015, which dismissed the petitioner’s complaint for recovery of ownership and possession of properties, accounting, and damages.
- The dispute originated after the death of Sancho Canada, who was the husband of the petitioner and had a common-law relationship with Cresencia Baclot.
Marital and Family Context
- Agrifina Canada and Sancho Canada were legally married on September 4, 1937, and had six children together: Elsa, Norma, Estrella, Yolanda, Rogelio, and Anacleta.
- Sancho left Agrifina in 1952 and commenced cohabitation with Cresencia, resulting in the birth of seven children: Sanchito, Roberto, Alfreda, Renato, Ronaldo, Ronel, and Rizalino, all carrying the surname Canada.
- The conflict escalated after Sancho passed away intestate on February 10, 1973, prompting Agrifina to seek legal action regarding the properties allegedly owned by Sancho.
Legal Proceedings and Claims
- Agrifina filed a complaint on May 16, 1994, seeking recovery of six parcels of land claimed to be owned by Sancho.
- Over the years, Agrifina amended her complaint to include additional properties and her children as plaintiffs.
- Cresencia responded with an answer that included specia