Title
Facturan vs. Sabanal
Case
G.R. No. L-2090
Decision Date
Sep 27, 1948
Dispute over property ownership: conjugal or private. Court of Appeals admitted excluded testimonies, ruled conjugal; Supreme Court upheld, citing presumption of conjugal property and inapplicability of statute of frauds.

Case Summary (G.R. No. L-2090)

Overview of the Legal Issue

The central legal issue pertains to the admissibility and relevance of corroborative testimonies regarding the acquisition of the property in question. The Petitioners contested the Court of Appeals' decision to consider those testimonies, which had been previously struck out by the trial court. The legitimacy of these testimonies was pivotal in establishing whether the contested property was part of the conjugal estate or the exclusive property of one spouse.

Trial Court's Decision

The trial court ruled to exclude certain corroborative testimonies, asserting that these were impermissible under the statute of frauds. This ruling was contested by the Petitioners, who argued that it was erroneous and detrimental to their case, as the testimonies would substantiate their claim concerning the nature of the property acquisition.

Appeals Court Ruling

The Court of Appeals reversed the trial court's decision, ruling that the testimonies were indeed relevant and did not fall under the statute of frauds. According to the Court of Appeals, the widow's testimony alone supported the presumption that the property in question was conjugal, thereby challenging the trial court's designation of the property as the exclusive property of Alfonso Facturan.

Statute of Frauds and Legal Presumptions

The legal argument raised included the application of the statute of frauds. The appellate court determined that this statute pertained only to executory contracts and did not apply to executed contracts like the sale in question. The Court of Appeals found that even assuming the testimonies were the sole pieces of evidence, they were sufficient to validate the presumption of conjugal property given the lack of contrary evidence.

Conclusion of Appellate Court and Denial of Reconsideration

Ultimately, the appellate court maintained that the lower court had erred in striking out the corroborative testimonies. Therefore, the court denied the motion for reconsideration filed by the Petitioners. It affirmed the principle that the ruling of the Court of Appeals was consistent with existing laws regarding marital property rights and the evidentiary rules governing such disputes.

Dissenting Opinion

A dissenting opinion contended that the trial court was correct in excluding the oral testimonies as they would undermine the statute of frauds. The dissent argued that allowing such testimonies withou

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