GR L 37420; (July, 1984) (Digest)
G.R. No. L-37420 & L-37421 July 31, 1984
MACARIA A. TORRES, petitioner, vs. COURT OF APPEALS, VICENTE SANTILLAN, ALFREDO NARCISO, TOMAS NARCISO, AMADO NARCISO, SALUD NARCISO, DEMETRIA NARCISO and ADELINA NARCISO, respondents.
FACTS
The controversy involves Lot No. 551, a friar land in Tanza, Cavite, originally leased and later sold under Sale Certificate No. 222 to Margarita Torres. Margarita was first married to Claro Santillan, with whom she had two children, Vicente and Antonina. After Claro’s death, she cohabited with Leon Arbole, and petitioner Macaria Torres was born in 1898. Margarita and Leon subsequently married in 1909. Leon paid the installments for the lot, and before his death in 1933, he executed a deed selling his rights to one-half of the lot to Macaria. After Margarita’s death, Vicente Santillan and the children of Antonina (the Narcisos) claimed the entire lot as Margarita’s exclusive heirs. They filed an ejectment case against Macaria, who in turn filed an action for partition, claiming the lot was conjugal property of Margarita and Leon and that she was their legitimated child entitled to a share.
ISSUE
The core issue is whether Macaria A. Torres is a legitimated child of Margarita Torres and Leon Arbole, entitled to inherit from Margarita’s estate, and whether Lot No. 551 is paraphernal property of Margarita or conjugal property of her marriage to Leon.
RULING
The Supreme Court ruled that Lot No. 551 is the conjugal property of the spouses Leon Arbole and Margarita Torres. The Court affirmed the legal principle that property acquired during a marriage is presumed conjugal. The Sale Certificate was issued in 1910, after their marriage in 1909, and installments were paid by Leon from his earnings, solidifying its conjugal nature. Consequently, upon Leon’s death, one-half of the property belonged to his estate, which he had validly conveyed to Macaria. The remaining half belonged to Margarita’s estate.
Crucially, the Court held that Macaria is the legitimated child of Margarita and Leon. Under the Civil Code, a child born out of wedlock who is subsequently acknowledged by the parents and whose parents later marry is considered legitimated. Macaria’s birth certificate and baptismal records, alongside the undisputed fact of her birth to Margarita and the subsequent marriage of her parents, established this status. Therefore, as a legitimated child, Macaria is entitled to inherit from Margarita’s estate alongside Margarita’s children from her first marriage, Vicente and Antonina (represented by her children, the Narcisos). The Court of Appeals erred in denying Macaria a share in Margarita’s half. The Supreme Court modified the appellate decision, adjudicating a total of four-sixths (4/6) of Lot No. 551 to Macaria: one-half (3/6) from her father Leon’s estate and an additional one-sixth (1/6) as her intestate share from her mother Margarita’s half, with the remaining two-sixths (2/6) going to Vicente and the heirs of Antonina.