G.R. No. 2873
FERMINA LEONARDO Y LEGASPI, petitioner‑appellee,
vs.
AMBROSIO SANTIAGO, ET AL., respondents‑appellants

FACTS
Fermina Leonardo y Legaspi instituted five separate proceedings (Nos. 1069‑1073) in the Court of Land Registration to have inscribed numerous tracts of land she claimed to own exclusively. The documents presented were Spanish government land grants issued to her husband, Nicomedes Santiago, and to herself. Ambrosio, Narciso, and Manuela Santiagochildren of Nicomedes by his first wifeobjected, asserting that the lands were acquired during the marriage and thus constituted conjugal property to which they were entitled as heirs. The trial courts ruled in favor of Fermina in each case. The respondents filed a single bill of exceptions, contending that the same legal issue prevailed in all actions. The evidence included: (1) Fermina’s testimony that she inherited the lands from her father before her marriage in 1884; (2) a public notice confirming this inheritance; (3) an inventory in Nicomedes’ will that omitted the lands; and (4) a written statement made by Nicomedes a month before his death acknowledging that the lands, though issued in his name, belonged to his wife’s inheritance and were held by him only as her representative. The respondents offered only the testimony of Narciso Santiago that Nicomedes had told him the land was bought jointly with the petitioner.

ISSUE
Whether the tracts of land, originally titled in the name of Nicomedes Santiago but claimed by his wife Fermina Leonardo y Legaspi as inherited property, constitute conjugal (partnership) property under Article 1407 of the Civil Code, or are the exclusive property of Fermina.

RULING
The Supreme Court affirmed the lower courts’ judgments in favor of Fermina. While the legal presumption is that property acquired during marriage is conjugal, the Court held that this presumption is rebuttable by clear proof. The petitioner’s inheritance testimony, corroborating public notice, the omission of the lands from Nicomedes’ will, and especially Nicomedes’ own written declarationadmissible under Sec. 282, CPC, as evidence against his pecuniary interestsufficiently overcame the presumption. The respondents’ evidence was deemed inadequate. Accordingly, the judgments were affirmed, costs were imposed on the appellants, and the case was remanded to the originating court for appropriate action.