GR 1056; (March, 1907) (Digest)
G.R. No. 1056 (March 13, 1907)
Facts
– Agueda Benedicto de La Rama filed a divorce action against her husband, Esteban de La Rama, on the ground of his adultery.
– The Court of First Instance (CFI) of Iloilo rendered a final judgment granting the divorce, ordering the husband to pay ₱81,042.76 as the plaintiff’s share of the conjugal partnership, plus ₱3,200 alimony.
– The husband appealed; the Philippine Supreme Court reversed the CFI, dismissing the complaint.
– The plaintiff then appealed to the Supreme Court of the United States, which reversed the Philippine Supreme Court and remanded the case, directing that the divorce issue be reconsidered.
– Upon remand, the Philippine Supreme Court again examined the divorce issue and ruled that no divorce was warranted, but the parties’ claims concerning the division of conjugal property and alimony remained unresolved.
– The appellant contended that (1) the CFI lacked jurisdiction to divide conjugal property in a divorce proceeding, and (2) the amount fixed for the plaintiff’s share was erroneous and should be reviewed despite the absence of a new‑trial motion.
Issue
1. Whether the CFI was authorized to adjudicate the liquidation and division of the conjugal partnership in a divorce action.
2. Whether the Supreme Court may re‑examine the CFI’s factual findings on the valuation of the conjugal property without a new‑trial motion under the Civil Procedure Code.
Ruling
The Court held that the United States Supreme Court’s remand addressed only the divorce decree; it did not strip the Philippine courts of authority to settle the conjugal partnership. Accordingly, the CFI’s jurisdiction to order the inventory and division of conjugal property was proper. The Court further ruled that, absent a valid motion for a new trial on the ground that the findings were “plainly and manifestly against the weight of the evidence,” the appellate court cannot re‑evaluate the factual determinations of the lower court. The evidence presented at trial sufficiently supported the valuation of ₱81,042.76, and the lower court’s findings were not manifestly contrary to the evidence. Hence, the judgment of the Court of First Instance on the division of the conjugal property was affirmed.