Erlinda Dinglasan Delos Santos v. Alberto Abejon

Summary

This family property dispute arose when Teresita used a forged deed of sale to transfer land owned by her sister Erlinda and brother-in-law Pedro (who died in 1989) to herself, then built a P2M building on the property. The Supreme Court applied conjugal partnership principles, holding that the loan obligation belongs to the conjugal partnership rather than the heirs directly. Finding both parties acted in bad faith regarding the building construction, the Court applied Civil Code accession rules, treating them as if both were in good faith. The case was remanded to determine proper indemnity for the building improvements while ordering restoration of the original land title and return of excess sale consideration.