Josephine B. Belcodero v. The Honorable Court of Appeals

Summary

This case involves a property dispute between legitimate and illegitimate family members over land acquired by Alayo D. Bosing during his marriage. After deserting his lawful wife Juliana and their three children in 1946, Alayo lived with Josefa Rivera and later bigamously married her. He purchased land in 1949 but had it titled in Josefa's name in 1959. After Alayo's death in 1967, Josefa and their daughter Josephine executed an extrajudicial partition treating the property as conjugal property and transferring full ownership to Josephine. The Supreme Court affirmed lower courts' decisions that the property belonged to the conjugal partnership with Alayo's legitimate wife Juliana under Civil Code provisions. The Court ruled that a constructive trust was created by operation of law when the illegitimate claimants fraudulently obtained the property, and the reconveyance action was filed within the applicable prescriptive period. The decision protects the property rights of legitimate heirs against fraudulent claims by common-law spouses.