Mendoza vs Reyes

[G.R. No. L-31618. August 17, 1983]

Facts:
 Julia Reyes executed a deed of sale of 2 parcels of land with their improvement in favor
of Efren and Inocencia Mendoza.
 Julia’s husband, Ponciano, filed a case before the CFI for the annulment of the subject
deed of sale. He claims that the said properties were conjugal and that she had sold it all
by herself without his knowledge or consent.
 The Mendoza spouses aver that the subject properties were the paraphernal properties
of Julia and that they had purchased the same in good faith and for adequate
consideration.

Issue:
W/N the subject properties are paraphernal properties of Julia?

Held:
No. The SC ruled that said properties are not paraphernal, but are conjugal in nature. This was
proven because of the loan obtained by the Reyes spouses jointly to complete the construction
of the improvement on the subject parcels of lands. Under Article 161 of the Civil Code, all debts
and obligations contracted by the husband and the wife for the benefit of the conjugal
partnership are liabilities of the partnership.

“There exists a presumption that all property of the marriage are presumed to belong to the
conjugal partnership, unless it be proved that they pertain exclusively to the husband or to the
wife. Properties acquired by onerous title during the marriage at the expense of the common
fund, whether the acquisition be for the partnership, or only one of the spouses are considered
conjugal partnership property.”