G.R. No. L-8938; October 24, 1914
PETRONA VILLORIA, plaintiff-appellee, vs. ESPERANZA AQUINO, defendant-appellant.

FACTS:
Petrona Villoria (plaintiff-appellee) filed an action to recover possession of seven parcels of land, alleging ownership and entitlement to possession, plus damages for illegal detention by Esperanza Aquino (defendant-appellant). Aquino, in her defense, claimed she was the possessor and real owner of the lands. The parties are related by affinity: Villoria is the mother-in-law of Aquino, and the lands were previously occupied by Aquino and her deceased husband, Genaro Corpus, who was Villoria’s son. Genaro Corpus died in September 1911, and the suit was filed in June 1912. During trial, Villoria presented conflicting evidence on the source of the propertyalternatively claiming it was given to Genaro by his father as a marriage gift or by his grandmother. Aquino, for her part, asserted the lands were a gift from her own mother at the time of her marriage. The evidence showed that Genaro Corpus and Aquino had occupied the lands during their marriage, and Genaro had declared them for taxation in his name as early as 1906. The lower court, unable to ascertain the precise origin of ownership, presumed the properties were conjugal property (bienes gananciales) and awarded one-half to Villoria as heir of her son, subject to Aquino’s usufruct over one-third of that half pursuant to Article 838 of the Civil Code. Aquino appealed.

ISSUE:
Whether the lower court correctly presumed the subject properties to be conjugal property (bienes gananciales) and properly divided them between the parties.

RULING:
Yes. The Supreme Court affirmed the lower court’s decision. When a husband and wife are in possession of real property as owners during their marriage, and the evidence fails to establish how they acquired it, the property is presumed to have been obtained during the marriage and thus constitutes conjugal property (bienes gananciales). Given the conflicting and inconclusive proof presented by both parties regarding the origin of the lands, the presumption applied. The division ordered by the lower courtawarding one-half to Villoria as heir, with a usufruct in favor of Aquino over one-third of that sharewas in accordance with the facts and the law. The judgment was affirmed with costs against the appellant.