G.R. No. L-2518

FACTS:
Hermenegildo Alfonso, as the judicial administrator of the estate of the deceased Pedro Angeles, filed an action for recovery of possession of two distinct parcels of land. The first parcel, located in Bunuhan, Pila, was in the possession of defendant Pedro Natividad. The second parcel, located in Santisima Cruz, Santa Cruz, was in the possession of defendant Silvestre Flores. The two claims were treated as separate controversies.

1. As to the land with Natividad: The land was registered in the name of Tomasa Mundanao, the wife of Pedro Angeles, during their marriage. In 1889, the spouses executed a document acknowledging a debt of 500 pesos received from Pedro Natividad and his wife, pledging the title deed to the Bunuhan land as security. The title deed was delivered to Natividad. Pedro Angeles died in 1889, and Tomasa died in 1901. After Tomasa’s death, Natividad took possession of the land, paid taxes, but did not cultivate it.

2. As to the land with Flores: This land originally belonged to the conjugal partnership of Pedro Angeles and Tomasa Mundanao. Before Pedro’s death, the spouses sold it to Alejandro Teodoro with a right of repurchase. After Pedro’s death, Tomasa, using her own funds, repurchased the property and later sold it to Silvestre Flores.

The trial court ruled in favor of both defendants.

ISSUE:
1. Who is entitled to liquidate the affairs of a conjugal partnership dissolved by the death of the husband, and consequently, who has the right to possess the partnership properties for that purpose?
2. Did the widow’s repurchase of a property previously sold with a right of repurchase, using her own funds after the husband’s death, inure to the benefit of the conjugal partnership or vest sole ownership in her?

RULING:
1. Regarding the land with Natividad: The Supreme Court REVERSED the trial court’s decision. The property, acquired during the marriage and registered in the wife’s name, is presumed to be conjugal partnership property under Article 1407 of the Civil Code. Upon the dissolution of the partnership by the death of the husband, its affairs must be settled. The Court ruled that this settlement should be conducted within the same judicial proceeding for the settlement of the husband’s estate. The administrator of the husband’s estate (the plaintiff-appellant) is therefore the proper person entitled to take possession of the conjugal partnership properties, including the land held by Natividad, for the purpose of liquidation. The document executed by the spouses and the delivery of the title deed to Natividad constituted only an equitable pledge of the document itself and did not create a lien on the land or a right to retain possession.

2. Regarding the land with Flores: The Supreme Court AFFIRMED the trial court’s decision. When Tomasa repurchased the property after her husband’s death, she did so with her own separate funds, not for the benefit of the dissolved conjugal partnership. This act of repurchase made her the sole owner of the property. Consequently, her subsequent sale to Silvestre Flores was valid, and the heirs of Pedro Angeles acquired no right to the property.

DISPOSITIVE PORTION:
The judgment was affirmed with respect to defendant Silvestre Flores. The judgment was reversed with respect to defendant Pedro Natividad, and the case was remanded to the trial court with instructions to enter judgment in favor of the plaintiff for possession of the Bunuhan property as property of the conjugal partnership. No costs were awarded.