Coja v. Aquillo
REITERATIONFacts
The Antecedents: Spouses Feliciano Sr. and Lorenza acquired a 120-square meter lot during their marriage. After Lorenza's death, Feliciano Sr. cohabited with Paz Lachica and married her shortly before his death. Paz Lachica later acquired another lot and sold a portion of it, leaving her with 151.9 square meters. Tax declarations were issued in Paz Lachica's name, eventually covering an increased area of 336 square meters, which included the original 120-square meter lot. Paz Lachica sold the 336-square meter property to petitioners Spouses Coja. Procedural History: Spouses Coja filed an application for registration of title. Luz Aquillo Victor, an heir of Feliciano Sr. and Lorenza, opposed the application, as did the OSG. Subsequently, the heirs of Feliciano Sr. and Lorenza filed an action for recovery of possession and ownership with damages against Paz Lachica and Spouses Coja. The two cases were consolidated. The RTC ruled in favor of Spouses Coja, dismissing the complaint and confirming their title. The CA reversed the RTC decision, nullifying the sale insofar as the heirs' shares were concerned, denying the registration, and ordering Spouses Coja to deliver possession and pay rent. The CA's motion for reconsideration was denied. The Petition: Petitioners Spouses Coja seek to reverse the CA decision, arguing that the CA erred in holding them as not the lawful owners, in concluding the land was not conjugal property, and in denying their application for registration. They contend that the property was Paz Lachica's paraphernal property, acquired before her marriage to Feliciano Sr., and that they were buyers in good faith.
Issue(s)
Whether the 120-square meter lot is conjugal property of Spouses Feliciano Sr. and Lorenza. Whether Paz Lachica could validly sell the entire 120-square meter lot to Spouses Coja. Whether Spouses Coja are entitled to the registration of title over the subject property. Whether the CA erred in reversing the RTC decision regarding co-ownership and partition.
Ruling
The petition is partially granted. The CA decision is affirmed with the modification that the order for petitioners to deliver possession of the property to respondents is deleted. Instead, the co-ownership between the parties over the subject 120-square meter property is recognized, with respondents having undivided shares of 93.3333 square meters and petitioners having undivided shares of 26.6666 square meters.
Ratio Decidendi
On the nature of the 120-square meter lot: The Court affirmed the CA's finding that the 120-square meter lot was conjugal property of Spouses Feliciano Sr. and Lorenza, as it was acquired during their marriage and declared for taxation purposes during that period. Article 160 of the Civil Code creates a disputable presumption that all property acquired during the marriage belongs to the conjugal partnership, unless proven otherwise. The burden of proof to rebut this presumption rests on the party asserting exclusive ownership, requiring strong, clear, categorical, and convincing evidence. Petitioners failed to provide such evidence to prove that the property was exclusively Paz Lachica's paraphernal property. On the validity of the sale by Paz Lachica: The Court held that Paz Lachica could only validly sell her rightful share in the 120-square meter property. Upon Lorenza's death, her share was transmitted to her heirs, including Feliciano Sr. Upon Feliciano Sr.'s death, his share, comprising his inheritance from Lorenza and his conjugal share, was transmitted to his heirs, including Paz Lachica. Consequently, Paz Lachica was only entitled to a portion (26.6666 square meters) of the 120-square meter lot, and the remaining portion (93.3333 square meters) belonged to the heirs of Feliciano Jr. and Luz. Therefore, Paz Lachica had no authority to sell the portions belonging to the respondents. On the registration of title and the CA's reversal: The Court agreed with the CA that Spouses Coja were not entitled to the registration of title over the entire property because Paz Lachica could not convey title to a portion that did not belong to her. The CA correctly reversed the RTC decision, recognizing the co-ownership that arose from the inheritance. On the nature of co-ownership and partition: The Court clarified that an action for recovery of possession by a co-owner against another co-owner who takes exclusive possession of the entire co-owned property only serves to recognize the co-ownership. The courts cannot proceed with the actual partitioning of the co-owned property in such an action. Judicial or extrajudicial partition is necessary to effect the physical division of the subject 120-square meter property. Therefore, the specific order for Spouses Coja to deliver possession of a specific portion was deleted, and instead, the co-ownership was recognized.
Main Doctrine
A tax declaration, even if revised or issued in the name of a spouse, does not operate to transfer title of a property that forms part of the conjugal partnership. Upon the death of a spouse, the conjugal partnership is terminated, and the property is transmitted to the heirs according to the rules of succession, creating a regime of co-ownership until partition.