Juana Agapito v. Candido Molo

Summary

This case involved a marital property dispute between spouses Juana Agapito and Candido Molo regarding the administration of the wife's paraphernal property. The husband was interfering with his wife's management of her separate property, prompting her to seek court intervention. The Court of First Instance of Manila issued a preliminary injunction granting the wife exclusive authority to administer her paraphernal property and retain net rental income as maintenance. On appeal, the Supreme Court affirmed the decision, emphasizing that under Article 1384 of the Civil Code, a wife has the right to administer her paraphernal property. The Court clarified that while income from paraphernal property belongs to the conjugal partnership, the wife's retention of net proceeds as spousal maintenance is legally justified, especially when spouses are living apart. This case establishes important precedent regarding marital property rights and the wife's administrative authority over her separate property.