Felisberto Gonzales · G.R. 46827

Citation: G.R. No. 46827
Court: Supreme Court En Banc
Division: En Banc
Decided: Enero 15, 1940

Summary

Supreme Court case affirming that real properties acquired by a married woman with her exclusive paraphernal funds remain her separate property and are not subject to attachment for her husband's personal debts. Felisberto Gonzales sought to enforce attachment of Lots 356 and 357 against Charles H. Miller's debt to Jose Malcampo. The Court applied Civil Code Articles 1407 and 1386, finding that despite the conjugal property presumption, Catalina Climaco's uncontradicted testimony proved she purchased the lots with her own money. The title certificates listing her as 'wife of Charles H. Miller' merely described her civil status rather than indicating joint ownership. The decision protects married women's separate property rights and limits creditors' remedies against paraphernal assets to their fruits only when family benefit is proven.

Statutes applied

Related cases

Other Philippine cases on the same provisions and issues.

Concepcion Abella de Diaz v. Erlanger & Galinger G.R. No. 38052
Margarita Quintos de Ansaldo v. The Sheriff of the City of Manila G.R. No. 43257
Isabela Colleges v. The Heirs of Nieves Tolentino-Rivera G.R. No. 132677
Staples-Howe Printing Company v. Manila Building G.R. No. 11994
Leocadio Joaquin v. Lamberto Avellana G.R. No. 4585

By Intellegal Editorial Board · Enero 15, 1940

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