Milagros Joaquino A.K.A. Milagros J. Reyes v. Lourdes Reyes

Summary

The Supreme Court resolved a property dispute between the legitimate spouse and children of deceased Rodolfo Reyes against his common-law wife Milagros Joaquino over a house and lot registered in Joaquino's name. The Court held that despite the registration in the paramour's name, the property constituted conjugal partnership property since it was acquired during the subsisting marriage using the husband's salaries and earnings. The registration was deemed a void donation under Civil Code Article 739, which prohibits donations between persons guilty of adultery or concubinage. The Court applied the constructive trust doctrine, requiring Joaquino to hold the property in trust for the legitimate spouse and heirs. Additionally, the Court affirmed that questions of illegitimate filiation and successional rights cannot be resolved in ordinary civil actions for property recovery but must be determined in proper probate or special proceedings designed for such purposes.