G.R. No. L-48978 May 27, 1981
Sebastian Enriquez, Crescencio M. Enriquez, Esso Philippines, Inc., and The Register of Deeds of Rizal, petitioners, vs. The Honorable Court of Appeals and Adalia J. Enriquez, respondents.

FACTS

The property in dispute is a 160-square-meter lot with an apartment building in Makati. Petitioner Sebastian Enriquez is married to private respondent Adalia J. Enriquez, and petitioner Crescencio is their son. The spouses acquired the property during their marriage, but the title was placed in Crescencio’s name upon Sebastian’s suggestion, allegedly because Sebastian was involved in litigation. The building, constructed through loans obtained by Crescencio using the lot as collateral, contained six apartments. The family lived in one unit, and Adalia collected rentals from the others until their separation in 1970.
In August 1970, Crescencio leased the entire property to Esso Philippines without Adalia’s knowledge. Esso demanded she vacate to demolish the building. Adalia filed suit, claiming the property was conjugal. Petitioners defended, arguing the property belonged exclusively to Crescencio as the registered owner and that Adalia’s action was barred by lack of jurisdiction, estoppel, laches, or prescription.

ISSUE

Whether the Court of Appeals erred in affirming the trial court’s declaration that the property is conjugal, entitling Adalia to a one-half share, corresponding rentals, and attorney’s fees.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The core legal issue was factual: determining the true ownership of the disputed property despite its registration in Crescencio’s name. The Court upheld the lower courts’ findings that the property was acquired during the marriage of Sebastian and Adalia, making it presumptively conjugal under the Civil Code. The titling in Crescencio’s name was a mere simulation, an arrangement to which Adalia agreed based on Sebastian’s representation.
Crucially, the Court found the factual conclusions of the Court of Appeals, which affirmed the trial court, to be supported by substantial evidence. This included Exhibits A and B—documents handwritten by Sebastian—which acknowledged Adalia’s rights as his lawful wife and her entitlement to a share in the property. Petitioners’ claim that these documents were later repudiated was not credited by the lower courts, and the Supreme Court found no compelling reason to overturn these credibility assessments. The loans for construction were ultimately paid from the property’s fruits (rentals), meaning Crescencio invested no personal funds. As the case primarily involved factual determinations, and petitioners failed to prove it fell under exceptions allowing Supreme Court review of facts, the petition was denied. All other assigned errors, being corollaries to the main issue, were likewise rejected.