G.R. No. 2260

FACTS:
Paula Roco (plaintiff-appellant) was married to Juan Crisostomo Villamil in 1891. In 1895, Villamil abandoned her and began cohabiting with Estefania Villar y Rivera (defendant-appellee). After Villamil’s death, Roco filed an action seeking a declaration that several parcels of land registered in Villar’s name were assets of her conjugal partnership with Villamil. She alleged fraud, claiming: (1) a lot conveyed directly by Villamil to Villar in 1896 was without consideration; and (2) the purchase money for six other lots conveyed to Villar by third parties between 1897 and 1900 was furnished by Villamil, with Villar contributing nothing. The trial court ruled in favor of Villar.

ISSUE:
Did the plaintiff-appellant present sufficient evidence to prove that the properties acquired in the name of the defendant-appellee were purchased with funds fraudulently contributed by the plaintiff’s husband, thereby constituting assets of the conjugal partnership?

RULING:
No. The Supreme Court affirmed the trial court’s judgment. The Court held that the evidence presented by the appellant was insufficient to overcome the presumption of regularity of the transactions and the title held by the appellee. The testimony of a witness regarding Villar’s prior poverty was too indefinite and casual to prove she lacked means to make the purchases in the relevant years (1896-1900). Furthermore, testimony that Villamil supervised construction on the lots did not constitute proof that he supplied the purchase money. The Court found no ground to reverse the trial court’s factual findings, as the evidence did not preponderate against its decision.