Mendoza v. Reyes (1983)

Mendoza v. Reyes

L-31618

August 17, 1983

Ponente: Justice Gutierrez, Jr.

FACTS

Pociano Reyes and Julia Reyes were married in 1915 and bought lots in Quezon City from JM Tuason on instalment basis. Due to the lack of money, the spouses found themselves in arrears for the payment of the instalments but managed to secure a loan from the Rehabilitation Finance Corporation jointly. To pay for the lots, the spouses executed corresponding deed of absolute sale where the vendee was named “Julia de Reyes,” duly signed by her where the phrase “with my marital consent” appeared over the Pociano’s name. The Transfer Certificate of Titles for the lots were registered in the Register of Deeds of Quezon City in the name of “Julia Reyes married to Pociano Reyes.” On March 3, 1961, Julia De Reyes sold the lots in question to the Mendoza spouses for P80,000.00 without the knowledge and consent of Pociano. At this time, Pociano and Julia were living separately and had no communication. This prompted Pociano to file a complaint for the annulment of a deed of sale of two parcels of land with their improvements executed by his wife Julia R. De Reyes (vendor) and spouses Efren V. Mendoza and Inocencia R. De Mendoza (vendees) with the COFI Rizal, alleging that the said properties were conjugal properties of him and Julia De Reyes, who had sold them to herein petitioners without his knowledge or consent. In their answers, the Mendoza spouses contend that the parcels of land were paraphernal properties of Julia De Reyes, a contention which the latter supports. The COFI Rizal, in dismissing the case, declared the properties exclusive and paraphernal properties of Julia De Reyes, which allowed her to validly dispose without the consent of her husband Felicano Reyes. On appeal, the Court of Appeals reversed the decision of the COFI, which prompted Julia De Reyes and the Mendoza spouses to file separate petitions for review, alleging that the Court of Appeals erred in declaring that the properties were conjugal properties of Julia De Reyes and Pociano Reyes. Julia De Reyes claims that she bought the two parcels of land on instalment basis, with the first payment as well as the entire purchase price and construction of the buildings, coming from her personal funds.

ISSUE/S:

- Whether or not the properties in question are conjugal properties.

HOLDING and RATIONALE:

YES.

Pursuant to Article 153 of the Civil Code, the Court found that there is no question that the property was acquired by onerous title during the marriage. Furthermore, it found that the funds used to buy the lot and build the improvements came from loans obtained by the spouses from the Rehabilitation Finance Corporation. Moreover, the presumption expressed in Article 160 of the same Code which states that unless proved otherwise, all property of the marriage is presumed to belong to the conjugal partnership. In this case, the petitioners were unable to establish clear and convincing evidence to rebut the conjugal character of the property having only Julia De Reyes’ testimony to offer. The Court ruled that the fact that the land is later registered in the name of only one of the spouses does not destroy the conjugal nature of the property. Likewise, the fact that the property acquired during marriage was registered in the name of the husband alone does not affect its conjugal nature, neither does registration in the name of the wife.  

JUDGMENT:

- Petitions for review are DENIED for lack of merit. The judgment of the Court of Appeals is affirmed.