G.R. No. 154645. July 13, 2004.
MILAGROS JOAQUINO a.k.a. MILAGROS J. REYES, petitioner, vs. LOURDES REYES, MERCEDES, MANUEL, MIRIAM and RODOLFO JR. — all surnamed REYES, respondents.

FACTS

Respondents, the legal wife and legitimate children of the late Rodolfo Reyes, filed a complaint for reconveyance and damages against petitioner Milagros Joaquino, Rodolfo’s alleged paramour. They alleged that a house and lot in Parañaque, registered under Joaquino’s name, was purchased using funds from Rodolfo’s salaries and retirement benefits, constituting conjugal partnership property of Rodolfo and his legal spouse, Lourdes. They asserted that Joaquino, who had no independent financial capacity, was merely a nominal owner, and that Rodolfo facilitated the mortgage and paid the amortizations.
Petitioner Joaquino claimed she purchased the property with her own exclusive funds. She asserted she cohabited with Rodolfo for 19 years without knowledge of his existing marriage to respondent Lourdes and that she had financial means from a drugstore business. She also claimed that her children with Rodolfo are entitled to a share in his estate.

ISSUE

The primary issue is whether the subject property, though registered in the name of the paramour, is conjugal property of the deceased and his legal spouse. A secondary issue is whether the filiation and successional rights of the paramour’s children can be adjudicated in this action for recovery of property.

RULING

The Supreme Court affirmed the Court of Appeals’ ruling, declaring the property as conjugal. The legal logic is anchored on the presumption that properties acquired during marriage are part of the conjugal partnership. The Court found that the purchase money indisputably originated from Rodolfo’s income as a corporate executive, which formed part of the conjugal partnership with his lawful wife, Lourdes. Registration in the paramour’s name does not overcome the presumption of conjugality, especially when the funds are proven to be conjugal. The paramour’s claim of exclusive ownership, supported only by self-serving affidavits from relatives, was insufficient to rebut the clear evidence of the fund’s origin.
Regarding the claim of Joaquino’s children, the Court ruled that their filiation cannot be settled in this summary action for reconveyance. Questions of illegitimate filiation must be resolved in a proper probate or special proceeding instituted specifically for that purpose, where evidence on paternity and successional rights can be fully ventilated. This action, being in personam, is not the proper vehicle to adjudicate the status and hereditary rights of alleged illegitimate children. The property is thus correctly declared conjugal, to be partitioned in accordance with the law on succession among the legitimate heirs.