Petitioner
Hermenegildo Alfonso
Respondent
Pedro Natividad
Citation
G.R. No. 2518
Court
Supreme Court
Division
First Division
Ponente
Willard, J.
Decided
April 30, 1906

Summary

Estate administrator brought action to recover two land parcels from defendants claiming conjugal partnership property. Supreme Court applied Civil Code Article 1407 presumption that marriage property belongs to conjugal partnership unless proven otherwise. For first parcel, Court ruled that despite title being in wife's name, absence of proof that purchase money was wife's separate property meant land belonged to conjugal partnership. Court held estate administrator, as representative settling deceased husband's estate, entitled to custody of conjugal partnership property. Delivery of title deeds as security for debt did not create possessory lien. For second parcel, Court affirmed that widow's post-death repurchase with separate funds gave her sole ownership, making subsequent sale valid. Case established important precedent on conjugal partnership property administration and estate settlement procedures under Spanish Civil Code.

Statutes applied

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By the Intellegal Editorial Board · April 30, 1906

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