This case clarifies property rights within a marriage, emphasizing that tax declarations alone are insufficient proof against the presumption of conjugal ownership when property is acquired during the marriage. Even if a subsequent tax declaration is issued solely in one spouse’s name, it does not automatically negate the conjugal nature of the property. The Supreme Court underscored that properties acquired during marriage are presumed conjugal unless compelling evidence proves otherwise. This ruling protects the inheritance rights of legitimate heirs and ensures equitable distribution of conjugal assets, underscoring the importance of tracing property acquisition to the time of the marriage to ascertain its true nature, regardless of subsequent tax declarations.

Unraveling Property Ownership: Can a Tax Declaration Overturn Conjugal Rights?

The case of Spouses Charlito Coja and Annie Mesa Coja versus the Heirs of Feliciano Aquillo, Sr. revolves around a disputed 336-square meter parcel of land. Paz Lachica sold this land to the Coja spouses. The heirs of Feliciano Aquillo Sr. contested the sale, asserting that a 120-square meter portion was conjugal property belonging to Feliciano Sr. and his deceased wife, Lorenza. The central legal question is whether Paz Lachica had the right to sell the entire property, including the portion claimed as conjugal by Feliciano Sr.’s heirs, and if a tax declaration in her name was sufficient to prove ownership.

At the heart of the dispute lies the presumption of **conjugal property**. Article 160 of the Civil Code states, “All property of the marriage is presumed to belong to the conjugal partnership, unless it be proved that it pertains exclusively to the husband or to the wife.” For this presumption to apply, it must first be proven that the property was acquired during the marriage.

The Court of Appeals determined that the 120-square meter portion was indeed acquired during the marriage of Feliciano Sr. and Lorenza. This triggered the statutory presumption in favor of the conjugal partnership. Therefore, the burden shifted to the Spouses Coja to prove that this portion was the exclusive property of Paz Lachica. The Supreme Court found that they failed to present clear and convincing evidence to overcome this presumption.

Petitioners argued that Paz Lachica exclusively owned the property because she had purchased it before marrying Feliciano Sr. However, the Court noted that while Paz Lachica did purchase land prior to her marriage, that purchase only accounted for a portion of the total 336 square meters that she later sold to the Coja spouses. The contested 120-square meter portion was covered by Tax Declaration No. 1151, which was issued in the name of Feliciano Sr. during his marriage to Lorenza.

The petitioners placed emphasis on Tax Declaration No. 3514, which was issued in Paz Lachica’s name after Feliciano Sr.’s death. This declaration included the 120-square meter lot previously covered by Tax Declaration No. 1151. However, the court emphasized that revising the tax declaration to include the property in her name did not transfer title. A tax declaration is not conclusive evidence of ownership; it merely provides a basis for tax assessment.

Furthermore, upon Lorenza’s death, the conjugal partnership dissolved. One half of the conjugal property, which included the 120 square meter lot, passed to her heirs. Her heirs included Feliciano Sr., Feliciano Jr., and Luz Aquillo. This division of property ownership further complicated Paz Lachica’s claim to the entirety of the land. Thus, she could only validly sell the portion of the 336-square meter parcel of land that rightfully belonged to her, not the portions that belonged to the heirs of Feliciano Sr. and Lorenza. It should be noted, however, that since co-ownership existed and the property was not yet partitioned, the Court did not compel Spouses Coja to surrender specific portions. The court then proceeded to recognize co-ownership, with corresponding undivided shares.

The court also explained how the dissolution of the conjugal partnership resulted in co-ownership between the involved parties. A situation exists under Article 996 of the Civil Code where part of the property goes to the heirs of Lorenza Mangarin, the deceased spouse. As the heirs of Feliciano Aquillo Jr. and Luz Aquillo, the heirs of the deceased are co-owners and entitled to a portion of the land.

What was the key issue in this case?	The main issue was whether a tax declaration in the name of one spouse could overturn the presumption that property acquired during the marriage is conjugal.
What is conjugal property?	Conjugal property refers to assets acquired by a husband and wife during their marriage through their work, industry, or from the fruits of their separate property. It is jointly owned by both spouses.
What is the legal presumption regarding property acquired during marriage?	The law presumes that all property acquired during the marriage belongs to the conjugal partnership unless proven otherwise. The burden of proof lies on the party claiming exclusive ownership.
What evidence is needed to overcome the presumption of conjugal property?	To overcome this presumption, strong, clear, categorical, and convincing evidence must be presented to prove that the property exclusively belongs to one of the spouses.
Is a tax declaration proof of ownership?	No, a tax declaration is not conclusive proof of ownership. It is primarily used for tax assessment purposes. Other evidence, such as deeds of sale, are necessary to establish ownership.
What happens to conjugal property upon the death of a spouse?	Upon the death of a spouse, the conjugal partnership is dissolved. One-half of the conjugal property goes to the surviving spouse, and the other half is inherited by the heirs of the deceased spouse.
Who are considered heirs in this case?	The heirs include the legitimate children of the deceased spouse and, in some cases, the surviving spouse who is entitled to a share equal to that of a legitimate child.
What is co-ownership, and how does it relate to this case?	Co-ownership is when two or more people own property together. In this case, when Lorenza died, her share of the conjugal property was transmitted to her heirs. This means a regime of co-ownership was established between the heirs.
What was the final ruling of the Supreme Court?	The Supreme Court affirmed the Court of Appeals’ decision, acknowledging the co-ownership of the property between the parties, but deleted the order compelling Spouses Coja to surrender specific portions until the co-owned property had undergone official partitioning.

The Spouses Coja case serves as a reminder of the importance of accurately tracing the acquisition of property within a marriage and the limitations of relying solely on tax declarations as proof of ownership. This decision reinforces the rights of legitimate heirs to inherit their rightful shares of conjugal property.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Spouses Charlito Coja and Annie Mesa Coja, vs. Hon. Court of Appeals and Heirs of Feliciano Aquillo, Sr., G.R. No. 151153, December 10, 2007