Edilberto U. Ventura, Jr. v. Spouses Paulino

Summary

This case involved a property dispute where Edilberto U. Ventura, Jr. challenged the sale of two properties by his step-grandfather Esteban Abletes to Esteban's daughter Evangeline and her husband. The key issue was whether Socorro Torres, Esteban's second wife, had ownership rights in the properties that could pass to her heirs. All three court levels ruled that Socorro's marriage to Esteban was void ab initio due to her prior subsisting marriage, and that she made no actual contribution to the acquisition of the properties, which were purchased before the void marriage. The Supreme Court affirmed that under Article 148 of the Family Code, only properties acquired through actual joint contribution during cohabitation can be considered common property. The Court emphasized that property registration merely confirms existing ownership and does not vest title, and that the burden of proof lies with the party asserting ownership rights.