In the Matter of the Testate Estate of Agapita Tiongson. Commonwealth of the Philippines v. Teodoro Sandiko As Administrator of the Estate

Summary

This landmark case establishes that properties acquired during marriage are presumed conjugal even if titled in one spouse's name alone. Teodoro Sandiko claimed three parcels of land purchased during his marriage to Mercedes Tiongson were his exclusive property to avoid inheritance taxes when Mercedes' sister Agapita inherited from Mercedes and later died. The Supreme Court affirmed the trial court's ruling that the properties were conjugal, applying Civil Code Article 1401's presumption that properties acquired during coverture are conjugal absent proof of exclusive funding by one spouse. The Court emphasized that obtaining individual title or registration certificates doesn't overcome the conjugal property presumption, and such property remains ganancial until the conjugal partnership is properly liquidated through legal proceedings.