Acre v. Yuttikki
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the ownership of properties acquired during the marriage of Sofronio Acre, Jr. and Evangeline Yuttikki. Sofronio was already married to Beatriz Acre when he married Evangeline in 1972, a union that lasted until Sofronio's death in 1996. The petitioners, who are the children of Sofronio and Beatriz, claim that Sofronio solely acquired the properties in question with his own funds during his marriage to Beatriz. 2. Procedural History: The petitioners filed a complaint for reconveyance and recovery of properties with the Regional Trial Court (RTC), Branch 58, Cebu City, alleging that Sofronio acquired the subject properties with his funds. The RTC dismissed their complaint, finding that the two parcels of land were owned in common by Evangeline and Sofronio. The petitioners appealed this decision to the Court of Appeals (CA). The CA, in a Resolution dated March 11, 2002, dismissed the appeal for lack of merit, affirming that one parcel of land was exclusively owned by Evangeline and the other was co-owned by Evangeline and her sister, Nellie Del Mar. 3. The Petition: The petitioners are seeking a review on certiorari under Rule 45 of the Rules of Civil Procedure, as amended, of the Decision of the Court of Appeals. They contend that the CA erred in declaring Evangeline Yuttikki as the owner of the contested properties. The petitioners argue that the marriage between Evangeline and Sofronio was bigamous, and thus their property regime should be governed by Article 148 of the Family Code, which requires actual joint contribution for co-ownership. They assert that they failed to present evidence of Sofronio's contribution to the acquisition of these properties.
Issue(s)
Whether the Court of Appeals erred in declaring respondent Evangeline Yuttikki the owner of the contested properties. Whether the properties acquired during the bigamous marriage between Sofronio Acre, Jr. and Evangeline Yuttikki are subject to co-ownership under Article 148 of the Family Code.
Ruling
The petition is denied, and the assailed Decision of the Court of Appeals is affirmed.
Ratio Decidendi
On the issue of the Court of Appeals' decision on ownership: The Supreme Court affirmed the Court of Appeals' ruling that the petitioners failed to prove by preponderance of evidence their entitlement to the properties in question. The certificates of title themselves, which showed the properties registered in the name of Evangeline Y. Acre, married to Sofronio V. Acre, Jr. (TCT No. 100087), and in the names of Evangeline Y. Acre, married to Sofronio Acre, and Nellie Y. Del Mar, married to Jose Del Mar (TCT No. 116740), indicate exclusive ownership by Evangeline and co-ownership with her sister, respectively. The words "married to" preceding Sofronio Acre, Jr. in the titles are merely descriptive of the civil status of the registered owner, Evangeline Y. Acre, and do not, by themselves, establish Sofronio's ownership or co-ownership of the properties without proof of his actual contribution. On the issue of co-ownership under Article 148 of the Family Code: The Court reiterated that the marriage between respondent Evangeline Yuttikki and Sofronio Acre, Jr. was bigamous, as it was celebrated while Sofronio was still married to Beatriz Acre. Consequently, their property regime is governed by Article 148 of the Family Code. This article provides that all properties acquired by the parties out of their actual joint contribution of money, property, or industry shall be governed by the rules on co-ownership. The Court emphasized that if there is no contribution from either or both of the spouses, there can be no co-ownership. The petitioners failed to present any evidence to establish that Sofronio made an actual contribution in acquiring the contested properties, thus co-ownership does not exist.
Main Doctrine
In a bigamous marriage, the property regime is governed by Article 148 of the Family Code, requiring actual joint contribution of money, property, or industry for co-ownership to exist. Certificates of title showing registration in the name of one party, with the spouse's name preceded by "married to," are merely descriptive of civil status and do not establish co-ownership without proof of contribution.