G.R. No. 221874 , July 07, 2020
AGRIFINA DULTRA VDA. DE CANADA, PETITIONER, VS. CRESENCIA BACLOT, SUBSTITUTED BY SANCHITO BACLOT, ROBERTO CANADA, ALFREDA PORTUGUEZ, RENATO CANADA, RONALDO CANADA, RONEL CANADA AND RIZALINO CANADA, RESPONDENTS.

FACTS

Spouses Sancho and Agrifina Canada (petitioner) were legally married in 1937. In 1952, Sancho left the conjugal home and entered into a common-law relationship with Cresencia Baclot, with whom he had seven children. Sancho died intestate in 1973. As the administrator of Sancho’s estate, petitioner filed a complaint in 1994 for recovery of ownership and possession of properties, accounting, and damages against Cresencia, seeking to recover several parcels of land allegedly owned by Sancho. The properties were registered either in the name of Cresencia Baclot or, in one instance, Sanchito Canada (Cresencia’s son). Cresencia claimed she acquired the properties through her own diligence and industry. The Regional Trial Court (RTC) ruled in favor of petitioner, ordering the delivery of the properties to Sancho’s lawful heirs (petitioner and her children). The Court of Appeals (CA) reversed the RTC, dismissing the complaint. The CA found that the properties were registered under Cresencia’s name (or her son’s), and petitioner failed to prove that Sancho contributed to their acquisition. Petitioner elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the subject properties, registered under the name of Cresencia Baclot (or her son), form part of the intestate estate of Sancho Canada and should be delivered to his lawful heirs.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Decision and Resolution of the Court of Appeals. The cohabitation between Sancho (who was validly married to petitioner) and Cresencia was governed by Article 148 of the Family Code, which applies retroactively. Under Article 148, only properties acquired by both parties through their actual joint contribution of money, property, or industry are owned in common in proportion to their respective contributions. The burden of proof rests on the party claiming co-ownership. In this case, the subject properties were registered under the name of Cresencia alone (except one under her son). Petitioner failed to present sufficient evidence to prove that Sancho made actual contributions to the acquisition of these properties. Consequently, Cresencia is declared the exclusive owner of the subject properties, and they do not form part of Sancho’s estate.