G.R. No. L-14309; June 30, 1960
CALTEX (PHILIPPINES) INC., petitioner, vs. FELISA FELIAS, respondent.
FACTS
Lot No. 107, Cadastral Survey of the City of Agusan, was originally owned by spouses Juliano Felias and Eulalia Felion. On March 31, 1928, they donated the lot to their daughter, respondent Felisa Felias, making it her paraphernal property, and Transfer Certificate of Title No. 97 was issued in her name. Felisa was married to Simeon Sawamoto. On March 26, 1941, a judgment was rendered against Simeon Sawamoto in Civil Case No. 1527 (Texas Company (Phil.), Inc. vs. Simeon Sawamoto) ordering him to pay a sum of money. To satisfy this judgment, the provincial sheriff levied upon Lot No. 107, together with its improvements and another coconut land parcel. On August 20, 1941, these properties were sold at public auction to the Texas Company, now petitioner Caltex (Philippines) Inc. The certificate of sale was annotated on the title. After the redemption period expired, a final deed of sale was executed in favor of Caltex on January 25, 1947, and recorded on the reconstituted title. On February 3, 1950, Felisa Felias filed an action to declare herself the exclusive owner of the two parcels. The trial court declared Lot No. 107 the exclusive property of defendant Vicente Dysekco (based on a contract of sale with right to repurchase) and declared the sheriff’s sale null and void, while declaring Caltex the exclusive owner of the coconut land. Both Felisa Felias and Caltex appealed. The Court of Appeals modified the trial court’s decision, declaring Felisa Felias the owner of Lot No. 107 and Caltex the exclusive owner of the coconut land. Caltex filed this petition for certiorari.
ISSUE
The primary issue is the status and ownership of Lot No. 107 at the time it was levied upon and sold by the sheriff—specifically, whether it was paraphernal property of Felisa Felias or conjugal property of the spouses, and thus subject to levy for the personal debt of the husband, Simeon Sawamoto.
RULING
The Supreme Court affirmed the decision of the Court of Appeals, declaring Felisa Felias the owner of Lot No. 107. The Court adopted the factual finding of the Court of Appeals that the lot was donated to Felisa on March 31, 1928, making it her paraphernal property. Crucially, the Court found that the building on the lot was constructed before the donation, while the lot still belonged to Felisa’s parents. Therefore, Article 1404 of the Old Civil Code (and its counterpart, Article 158 of the New Civil Code), which provides that buildings constructed during the marriage on the land of one spouse belong to the conjugal partnership (subject to reimbursement for the land’s value), was not applicable. Since the building was an accessory to the land, and the land was donated to Felisa after the building’s construction, the lot became her paraphernal property, carrying with it the rights over the building constructed thereon. Consequently, at the time of the levy and sheriff’s sale, Lot No. 107 was Felisa’s paraphernal property and was not answerable for the personal obligations of her husband, Simeon Sawamoto. The Court noted that the building was destroyed during the war and no longer existed at the time of the final sheriff’s deed in 1947. The sheriff’s sale of Lot No. 107 was therefore invalid. The decision was affirmed on this ground.