G.R. No. L‑3629
September 28 1907

PARTIES Matea E. Rodríguez (plaintiff‑appellant) vs. Susana de la Cruz, Escolástico de la Cruz and Procesa de la Cruz (defendants‑appellees).

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FACTS
1. Matea Rodríguez claimed ownership of several parcels of land which she asserted she inherited from her father, Alejo Rodríguez, during her first marriage.
2. She married Hilarion de la Cruz (second husband) and, with his consent, instituted an action in the Albay Court of First Instance to recover the lands from the defendants.
3. During the pendency of Rodríguez’s case, the defendants filed a separate partition suit against Hilarion de la Cruz (the father of the defendants). That suit resulted on 29 Mar 1905 in a judgment awarding portions of the lands to Susana de la Cruz and to Escolástico de la Cruz.
4. Rodríguez was not a party to the partition suit and asserted she had no knowledge of it.
5. The trial court ruled for the defendants, holding that the lands were acquired by Hilarion de la Cruz during his first marriage to Andrea de Leon and that Rodríguez thus had no title.

Rodríguez appealed, alleging errors in the trial court’s findings on (a) the effect of her non‑participation in the partition suit, (b) the legal implication of her husband’s administration of the lands, and (c) the factual determination that the lands were not inherited from her father.

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ISSUE
Whether the trial court erred in (1) concluding that Rodríguez’s failure to be joined as a party to the partition action extinguished her alleged ownership, (2) treating her husband’s administration of the lands as a transfer of title to him, and (3) finding that the lands were not her inheritance from her father.

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RULING
1. Section 277, CPC A judgment against one person does not affect the rights of another who was not a party. Since Rodríguez was not joined in the partition suit and had no notice thereof, the earlier judgment could not defeat her claim.

2. Civil Code on marital property – Art. 1382 A wife retains ownership of property she brings into the marriage.
– Art. 1384 Administration of her property by the husband is permissible only by public conveyance; mere administration does not transfer ownership.

The trial court improperly inferred title by virtue of Hilarion de la Cruz’s long‑term administration.

3. Evidence of inheritance The appellate court found, after reviewing the trial record, that the lands were indeed inherited by Rodríguez from her deceased father during her first marriage, contrary to the trial court’s finding.

Accordingly, the Supreme Court reversed the judgment of the Court of First Instance and remanded the case with direction to enter judgment declaring Matea E. Rodríguez as owner and in possession of the lands described in the amended complaint, against the defendants. No award of costs was made.

Concurrence: Chief Justice Arellano, and Justices Torres, Willard, and Tracey.