Spouses Rollijun v. Candelaria Reyes Vda. de San Juan

Summary

This Supreme Court case involves a property dispute over land inherited by Victorina San Juan from her father in 1975. After Victorina's death in 2006, her husband Graciano executed an Affidavit of Adjudication claiming sole ownership and sold the property to Spouses Torio for PHP3.8 million. Victorina's mother Candelaria challenged this, claiming the property was Victorina's paraphernal property subject to intestate succession. The Supreme Court ruled that the property remained Victorina's exclusive property acquired by lucrative title (inheritance) under Article 148(2) of the Civil Code, creating ordinary co-ownership between Candelaria and Graciano upon Victorina's death. The sale was valid only as to Graciano's ideal share, making Spouses Torio co-owners with Candelaria's surviving heirs. The decision clarifies that property acquired by inheritance during marriage remains separate property and establishes important precedent on co-ownership rights in inherited property.