SUBJECT: TOPIC: CASE NAME:

Persons Exclusive Property Rodriguez v. De la Cruz

RELEVANT PROVISIONS:
Art. 109. The following shall be the exclusive property of each spouse:
(1) That which is brought to the marriage as his or her own;
(2) That which each acquires during the marriage by gratuitous title;
(3) That which is acquired by right of redemption, by barter or by exchange with property belonging to only one of
the spouses; and
(4) That which is purchased with exclusive money of the wife or of the husband. (148a)

Art. 110. The spouses retain the ownership, possession, administration and enjoyment of their exclusive properties.
Either spouse may, during the marriage, transfer the administration of his or her exclusive property to the other by
means of a public instrument, which shall be recorded in the registry of property of the place the property is located.
(137a, 168a, 169a)
PONENTE: Johnson Case Date: September 28, 1907

DETAILED FACTS:
Plaintiff Matea Rodriguez filed an amended complaint in the CFI of Albay for the purpose of recovering
from the defendants certain parcels of land.
She claims that she acquired ownership of the said lands during her first marriage from her deceased
father, that she had permission from Hilarion de la Cruz, her second husband, to commence this action in
her own name against his children, and that Hilarion had been administering the said lands during their
marriage.
Prior to plaintiffs filing of complaint, the defendants filed an action in the CFI of Albay against Hilarion for
the partition of the disputed lands. The CFI ruled in favor of the defendants. The defendants in the case at
bar, in their reply to plaintiffs complaint, used as a defense the said judgment of the CFI of Albay.
The lower court found that the disputed lands were acquired by Hilarion during his marriage with his first
wife, and that the lands were not inherited by the defendants from the plaintiffs father.

ISSUE:
(1) W/N Hilarion was the owner of said lands
since he had been administering the lands in
question during the entire period of his
marriage to Matea.
(2) W/N the CFI Albay err in finding that Hilarion
acquired the land in question during his
marriage to Andrea de Leon.
RULING:
Lower court decision reversed.
HOLDING:
(1) No. There is no provision in the Civil Code which
prohibits a husband from administering the property of his
wife. Just because he has been administering it for a long
time doesnt mean it is his. The mere fact that she had
permitted her husband to administer her property (even
without delivering the same to her husband by means of a
public document1) oes not mean that she has forfeited the
same in favor of her husband.
(2) Yes. SC examined the evidence adduced during the lower
court trials and found that the lands in question were
acquired by Matea from her deceased father through
inheritance. Cause remanded to the lower court with
direction that a judgment be entered declaring that the said
plaintiff is the owner.

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