G.R. No. L-7546; June 30, 1955
Intestate Estate of the deceased Francisco T. Ramos. CECILIA RAMOS SILOS, ET AL., petitioners-appellants, vs. MARIA LUISA RAMOS, ET AL., oppositors-appellees.

FACTS

Jose Ramos Silva and Margarita Tanate died intestate, leaving seven children (Paz, Asuncion, Dolores, Gregoria, Engracia, Agripina, and Francisco Ramos) and considerable property, including Hacienda Aguisan. In the project of partition approved by the court on December 1, 1914, the estate was valued at P106,750.35, with Hacienda Aguisan valued at P27,400 (plus P7,000 for improvements). Each heir’s share was P15,250.05. Francisco Ramos was adjudicated properties totaling P52,327.22, which included Hacienda Aguisan. To equalize the shares, Francisco agreed to pay his six sisters specific sums, which he paid in 1918. Francisco had married Dolores Garcia on May 28, 1914, before the partition. The cadastral court later adjudicated the hacienda lots to “Francisco T. Ramos, married to Dolores Garcia.” Upon Francisco’s death, a dispute arose: his widow and legitimate children claimed the hacienda was conjugal property, while his acknowledged natural daughter and other heirs claimed it was his exclusive property. The trial court declared 6/7 of the hacienda as conjugal property.

ISSUE

Whether Hacienda Aguisan, or portions thereof, constitutes exclusive property of Francisco Ramos or conjugal property of his marriage with Dolores Garcia.

RULING

The Supreme Court affirmed the trial court’s decision, holding that 6/7 of Hacienda Aguisan belonged to the conjugal partnership of Francisco Ramos and Dolores Garcia. The Court ruled that: (1) Articles 450 and 1068 of the old Civil Code only apply to Francisco’s original 1/7 share as an heir, not to the remaining 6/7; (2) the transaction for the 6/7 portion was a purchase and sale, not a barter, as Francisco paid his co-heirs in cash; (3) the funds for this purchase came mainly from the hacienda’s sugar proceeds during his marriage, constituting conjugal funds; (4) Article 1062 on indivisibility did not apply, as the hacienda could have been partitioned; and (5) the cadastral adjudication to Francisco alone did not negate the conjugal nature, as property acquired during marriage is presumed conjugal. Thus, the 6/7 portion acquired using conjugal funds during the marriage belonged to the conjugal partnership.