PEÑA, TABITHA ERLINDA MA. PAS A.

CASE DIGEST

MENDOZA vs. REYES

G.R. No. L-31618. August 17, 1983.
Gutierrez, Jr. J.

FACTS:

1. Ponciano Reyes and Julia Reyes are husband and wife who were married in 1915—They
bought on installment basis two parcels of land in Quezon City in 1947.
2. The Deed of Absolute Sale of said parcels of land was eventually executed to them after
having been in arrears in the payment of installments that caused them to execute
mortgage contracts so as to obtain loans that would help them complete payment.
3. In the Deed of Sale, Julia’s signatures appear over the caption vendee and Ponciano’s
under: “with my marital consent.”—As such, the Register of Deeds issued Transfer
Certificates of Title in the name of ‘JULIA REYES married to PONCIANO REYES.’
4. Sometime in March 1961, while Ponciano was managing his farm in Pampanga, Julia
sold said parcels of land to Sps. Efren and Inocencia Mendoza without Ponciano’s
consent. (At the time, Ponciano and Julia were living separately and not in speaking
terms.)
5. As a result, Ponciano filed with the trial court a complaint about his wife Julia’s
execution of a Deed of Sale to Sps. Mendoza, averring that said properties which were
sold without his consent and at the same time claimed by his wife to be paraphernal in
nature are, in fact, conjugal properties.
6. In response, Julia claimed: that she bought said properties on installment basis; that the
first payment came from her personal funds; and that she paid the entire purchase price as
well as constructions also with her personal funds.
7. The trial court dismissed the complaint and declared said properties in question as
paraphernal and exclusive properties of Julia; hence, Julia may validly dispose of said
properties without the consent of her husband Ponciano.
8. The trial court’s decision was, however, reversed by the Court of Appeals, thereby
declaring said properties as conjugal properties.

ISSUE:

W/N the properties in question are conjugal properties

RULING:

YES. Property acquired during a marriage is presumed to be conjugal and the fact that the
land is later registered in the name of only one of the spouses does not destroy its conjugal
nature. The fact that property acquired during marriage was registered in the name of the
husband alone does not affect its conjugal nature.

*** It is only when there is a squabble over property, much later from its acquisition, not
necessarily between the spouses, or with the buyer, but may also be between their heirs or
creditors that proof of ownership becomes a contentious issue. By this time, it may be too late to
recover evidence that can no longer be found. Hence, there is only the presumption to go by. In
many instances, the presumption becomes determinative of ownership of a property of a
marriage. The presumption is a strong one. (Gesmundo, p. 297)