Citation
G.R. No. 47507
Court
Supreme Court En Banc
Division
En Banc
Decided
Diciembre 19, 1940

Summary

This interpleader case resolved a payment dispute involving parafernal property rights in marriage. Elena owned four urban lots before marriage and sold them with her husband's consent to Rosario Lim Queco under an installment contract. After the spouses separated and the husband obtained a Mexican divorce and remarried, confusion arose over who should receive the monthly payments. The Supreme Court affirmed that Elena, as owner of parafernal property, retained administration rights and should receive the payments. The Court emphasized that parafernal property remains under the wife's administration unless formally transferred to the husband, and that the husband's collection of P820.61 in payments exceeded his contribution to improvements. The decision reinforced the Civil Code's protection of married women's separate property rights and clarified the administration of parafernal versus conjugal property in dissolved marriages.

Statutes applied

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By Intellegal Editorial Board · Diciembre 19, 1940

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