Perido v. Perido
REITERATIONFacts
1. The Antecedents: This case concerns the estate of the deceased Lucio Perido, who was married twice. His first marriage to Benita Talorong produced three children: Felix, Ismael, and Margarita. After Benita's death, Lucio married Marcelina Baliguat, with whom he had five children: Eusebio, Juan, Maria, Sofronia, and Gonzalo. The dispute centers on the legitimacy of Lucio's children with Marcelina and the ownership of several lots that were partitioned via an "Declaration of Heirship and Extra-judicial Partition" executed by the heirs of both marriages. The children of the first marriage, or their descendants, alleged they were induced by fraud to sign the partition and claimed the lots were exclusively conjugal property of Lucio and Benita, and that Lucio's children with Marcelina were illegitimate. 2. Procedural History: The children and grandchildren of Lucio Perido's first marriage filed a complaint in the Court of First Instance of Negros Occidental seeking to annul the "Declaration of Heirship and Extra-Judicial Partition." The trial court annulled the partition but declared the children of the second marriage legitimate and determined the ownership of the lots, dividing them among the heirs. The plaintiffs appealed this decision to the Court of Appeals, arguing that the trial court erred in declaring the children of the second marriage legitimate and in its findings regarding the ownership of the disputed lots. The Court of Appeals affirmed the trial court's decision in its entirety. The petitioners then filed the instant petition for review with the Supreme Court, reiterating their assignments of error. 3. The Petition: The petitioners seek review of the Court of Appeals' decision affirming the trial court's ruling. Their petition raises three main issues: (1) the legitimacy of Lucio Perido's five children with his second wife, Marcelina Baliguat; (2) whether certain lots (Nos. 471, 506, 511, 509, 513-Part, 807, and 808) were the exclusive properties of Lucio Perido or the conjugal property of his first marriage; and (3) whether a portion of Lot No. 458 was conjugal property of Lucio Perido and his second wife. The petitioners argue that the children of the second marriage were illegitimate and that the lots in question were acquired during the first marriage. The Supreme Court, however, found no reversible error, upholding the Court of Appeals' findings that the evidence supported the legitimacy of the children and the ownership of the lots as determined by the lower courts, emphasizing that factual findings of the Court of Appeals are generally not subject to review on certiorari.
Issue(s)
Whether the children of Lucio Perido with his second wife, Marcelina Baliguat, are legitimate. Whether Lots Nos. 471, 506, 511, 509, 513-Part, 807, and 808 were the exclusive properties of Lucio Perido or conjugal property of Lucio Perido and his first wife, Benita Talorong. Whether 11/12 of Lot No. 458 was the conjugal partnership property of Lucio Perido and his second wife, Marcelina Baliguat.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, upholding the legitimacy of the children from the second marriage and the property classification as determined by the lower courts. The Court dismissed the petition for review for lack of reversible error.
Ratio Decidendi
On the legitimacy of the children of Lucio Perido with Marcelina Baliguat: The Court held that the Court of Appeals' finding that Benita Talorong died during the Spanish regime was conclusive. This meant Lucio Perido had no impediment to marry Marcelina Baliguat before the birth of their first child in 1900. The Court also upheld the presumption of marriage, stating that persons living together as husband and wife are presumed to be married, and this presumption can only be overcome by cogent proof. The statement of Lucio Perido's civil status in 1923 certificates of title was deemed insufficient to rebut this presumption. The Court noted that the alleged 1925 marriage ceremony was not even passed upon by the lower courts, and the testimony regarding it was uncorroborated and lacked eyewitness accounts. Therefore, the five children of Lucio Perido and Marcelina Baliguat were correctly declared legitimate. On the classification of Lots Nos. 471, 506, 511, 509, 513-Part, 807, and 808: The Court reiterated that the appreciation of evidence is within the domain of the Court of Appeals, and its factual findings are not subject to review by the Supreme Court. The appellate court's finding that these lots were inherited by Lucio Perido from his grandmother, making them his exclusive properties, was based on evidence presented, including certificates of title and testimony. The petitioners' contention that these lots were acquired during the first marriage was an issue of fact that the CA had already resolved against them. Thus, the Supreme Court could not disturb this finding. On the classification of 11/12 of Lot No. 458: The Court found no error in the appellate court's ruling that Lot No. 458 was conjugal property of Lucio Perido and his second wife, Marcelina Baliguat. The certificate of title for this lot, issued in 1925, expressly stated that Lucio Perido was married to Marcelina Baliguat, unlike previous titles. The Court reinforced the legal presumption that property registered in the name of one spouse is conjugal, and this presumption is even stronger when the title explicitly mentions the spouse. The petitioners failed to present clear proof to overcome this presumption. The issue of whether portions of this lot were conjugal with the first wife or acquired from proceeds of sale of other properties involved appreciation of evidence, which was within the CA's purview and thus binding on the Supreme Court.
Main Doctrine
The Court affirmed the Court of Appeals' decision, upholding the legitimacy of children born during a subsequent marriage and the classification of properties as either exclusive or conjugal based on evidence and legal presumptions, particularly the presumption of marriage and the conclusiveness of factual findings by lower appellate courts.