Corpuz vs. Corpuz

A surviving spouse does not become de facto administrator of conjugal property upon the other spouse’s death; under Act No. 3176, a sale of conjugal property without liquidation or partition is void except as to the vendor’s share. Thus, Francisco Corpuz’s sale after Bernarda Mantile’s death conveyed only his share, and her heirs were not divested.

Evaristo Corpuz is one of the children of Francisco Corpuz and Bernarda Mantile. Susana Corpuz is the judicial guardian of the children of Isabelo Corpuz, who are the heirs of Domingo Cruz and Eugenia Rigal. Act No. 3176, effective in 1924, governs the administration and liquidation of conjugal property when the marriage is dissolved by death.

The property in dispute is a parcel of land of about 1,854 square meters covered by Original Certificate of Title No. 5980 of the land records of Nueva Ecija. By a deed executed on November 12, 1934, some eleven years after Bernarda Mantile’s death, Francisco Corpuz conveyed the land by way of sale to the spouses Domingo Cruz and Eugenia Rigal for the sum of P80. The deed described the land as registered under Original Certificate of Title No. 5980 in the name of Francisco Corpuz and Bernarda Mantile “y difunta.” The dispute is between an heir of the wife of the vendor and the heirs of the vendees.

The vendees had an only son named Isabelo Corpuz, who married Susana Santiago and had three children with her. In 1943, with Domingo and his son Isabelo already deceased, their widows Eugenia Rigal and Susana Santiago had a misunderstanding and, for that reason, the certificate of title to the property in dispute was, together with other documents, entrusted by them to the mayor of Rizal, Nueva Ecija. Upon the death of the latter during the Japanese occupation the title was lost, and with a view to securing a duplicate thereof, Susana Santiago enlisted the help of Evaristo Corpuz, one of the children of the vendors.

Pretending to help Susana, Evaristo secured a duplicate certificate of title for himself and, once it was obtained, refused to deliver it to Susana, telling her that they had better litigate the matter in court. Susana then filed the present action in her capacity as judicial guardian of her children, all minors, who, with the deceased Isabelo Corpuz, were the only heirs of the deceased Domingo Corpuz and Eugenia Rigal. The complaint prayed that Evaristo be ordered to deliver to plaintiff the second Owner’s Duplication Certificate of Title which he obtained from the Register of Deeds; that he be declared without right to possess the duplicate because the land covered by it had already been conveyed to Domingo Corpuz; and that damages and costs be adjudged to plaintiff.

Answering the complaint, Evaristo alleged that the deed of sale supposed to have been executed by Francisco Corpuz in favor of Domingo Corpuz and his wife was fictitious and void and that, in any event, the vendor had no authority to make the sale because the land sold was conjugal property. He alleged that Bernarda Mantile died intestate in 1923, long before the sale, and that he and his brothers and sisters Daniel, Inocencio, Narciso, Escolastica, Canuta, and Felicidad, all surnamed Corpuz, had by operation of law become the owners of one-half of the land in question through inheritance from their deceased mother.

• Fictitious Sale: Petitioner alleged that the deed of sale supposedly executed by Francisco Corpuz in favor of Domingo Corpuz and his wife was fictitious and void.
• Lack of Authority over Conjugal Property: Petitioner alleged that the vendor had no authority to make the sale because the land was conjugal property; Bernarda Mantile died intestate in 1923, before the sale, and petitioner and his siblings became owners of one-half of the land by operation of law through inheritance from their deceased mother.

• Ownership Under the Sale: Respondent maintained that the land covered by the duplicate certificate had already been conveyed to Domingo Corpuz, so Evaristo had no right to possess the duplicate.
• Delivery of Duplicate Certificate: Respondent sought an order requiring Evaristo to deliver the second Owner’s Duplication Certificate of Title to her.
• Damages and Costs: Respondent sought damages and costs.

• Validity and Extent of Sale of Conjugal Property: Whether the sale by Francisco Corpuz of conjugal land after Bernarda Mantile’s death, without liquidation or partition, conveyed the entire property or only the vendor’s share under Act No. 3176.
• Possession of Duplicate Certificate of Title: Whether the heirs of the vendees are entitled to exclusive possession of the duplicate Torrens certificate of title, or whether the certificate should be held for both sets of heirs as co-owners.
• Damages: Whether Evaristo’s claim for damages referring to the products of the land may be adjudicated in the present case without joining his co-heirs.

• Validity and Extent of Sale of Conjugal Property: Partially. The sale conveyed title only to Francisco Corpuz’s share; under Act No. 3176, a sale of conjugal property without liquidation or partition is void except as to the vendor’s share, so Bernarda Mantile’s heirs were not divested.
• Possession of Duplicate Certificate of Title: No. The heirs of the vendees are not entitled to exclusive possession of the Torrens certificate; with the property jointly owned by both sets of heirs, title should first be recorded in their joint names through appropriate procedure.
• Damages: No. The claim for damages referring to the products of the land cannot be adequately adjudicated because the co-heirs who should share equally were not made parties.

• Validity and Extent of Sale of Conjugal Property: The deed described the land as registered under Original Certificate of Title No. 5980 in the names of Francisco Corpuz and Bernarda Mantile “y difunta,” so the land was presumed conjugal, and the presumption stood because no proof to the contrary appeared. Francisco declared himself absolute owner merely because his wife was already dead. The CA’s view that the surviving husband, as administrator of the community property, could sell conjugal property without the concurrence of the children was inaccurate because Act No. 3176, which took effect in 1924, had already been approved at the time of the 1934 sale. Under that Act, when the marriage is dissolved by death, the community property shall be administered and liquidated in the testamentary or intestate proceedings of the deceased spouse, or in an ordinary liquidation and partition proceeding. No liquidation or partition was made, and the death of the wife did not make the husband the de facto administrator of the conjugal estate or invest him with power to dispose of it. The Act declares that a sale without the formalities established for the sale of the property of deceased persons “shall be null and void, except as regards the portion that belongs to the vendor at the time the liquidation and partition was made.” The cases cited by the CA were either decided before the approval of the Act or referred to sales antedating its approval and were not controlling. Ocampo et al. vs. Potenciano et al. held that the surviving spouse had no such authority as de facto administrator and that the older decisions relied on by the CA were obsolete. Therefore, the sale by Francisco Corpuz conveyed title only to his share, and the legal heirs of Bernarda Mantile were not divested of her share.

• Possession of Duplicate Certificate of Title: With the property jointly owned by the heirs of the vendor’s deceased wife and the heirs of the vendees, the latter set of heirs were not entitled to exclusive possession of the Torrens certificate of title then in the possession of defendant, who was one of the other set of heirs. Plaintiff’s remedy might be to ask for another Owner’s Duplicate Certificate, but before that was done, title to the property should first, through appropriate procedure, be recorded in the joint names of both sets of heirs as co-owners.

• Damages: Defendant’s claim for damages, referring to the products of the land, could not be adequately adjudicated in the present case because his co-heirs, who should have equal interest in such damages, had not been made parties and could not be bound by any adjudication that might be made on said claim.

• Surviving Spouse as De Facto Administrator — Act No. 3176 changed the rule that the surviving spouse becomes de facto administrator of conjugal property upon the other spouse’s death; the property must be administered and liquidated in testamentary or intestate proceedings or in an ordinary liquidation and partition proceeding. The SC applied this to hold that Francisco Corpuz’s sale after Bernarda Mantile’s death did not bind her heirs.
• Sale of Conjugal Property Without Liquidation — A sale of conjugal property without the formalities established for the sale of deceased persons’ property is null and void except as regards the portion belonging to the vendor at the time of liquidation and partition. The SC applied this to uphold the sale only as to Francisco Corpuz’s share.
• Presumption of Conjugal Property — Land registered in the names of both spouses is presumed conjugal, and the presumption stands absent proof to the contrary. The SC applied this because OCT No. 5980 was in the names of Francisco Corpuz and Bernarda Mantile “y difunta,” and no contrary proof appeared.
• Co-Ownership and Possession of Torrens Certificate — When property is jointly owned by the heirs of the deceased wife and the heirs of the vendees, the vendees’ heirs are not entitled to exclusive possession of the Torrens certificate; title should first be recorded in the joint names of both sets of heirs as co-owners. The SC applied this to deny the vendees’ heirs exclusive possession of the duplicate certificate held by Evaristo.
• Damages and Indispensable Parties — A claim for damages belonging to co-heirs cannot be adequately adjudicated without joining those co-heirs, who cannot be bound by any adjudication made in their absence. The SC applied this to refuse adjudication of Evaristo’s claim for the products of the land.

• “when the marriage is dissolved by the death of the husband or wife, the community property shall be administered and liquidated in the testamentary or intestate proceedings of the deceased spouse, or in an ordinary liquidation and partition proceeding.” — This states the Act No. 3176 rule that the SC used to reject the CA’s de facto administrator theory.
• “shall be null and void, except as regards the portion that belongs to the vendor at the time the liquidation and partition was made.” — This defines the effect of a sale made without the required formalities and supports the partial validity of Francisco’s sale.
• “the sale made by Francisco Corpuz of the land covered by Original Certificate of Title No. 5980 should be held to have conveyed title only to the vendor's share in said land, with the result that the legal heirs of the deceased Bernarda Mantile cannot be deemed to have been divested of their title to her share of the property.” — This is the ratio on the extent of the sale.
• “With the property jointly owned by the heirs of the vendor's deceased wife and the heirs of the vendees, the latter set of heirs are not entitled to have exclusive possession of the Torrens certificate of title now said to be in the possession of the defendant, who is one of the other set of heirs.” — This explains why the SC revoked the order to surrender the duplicate certificate.

• Ocampo et al. vs. Potenciano et al., 89 Phil. 159 (L-2263, May 30, 1951) — Followed; the SC relied on it to hold that the surviving spouse had no authority as de facto administrator of the conjugal estate and that the older decisions relied on by the CA were obsolete.

• Act No. 3176 — Declared that upon dissolution of the marriage by death, the community property shall be administered and liquidated in the testamentary or intestate proceedings of the deceased spouse, or in an ordinary liquidation and partition proceeding; a sale without the formalities for sale of deceased persons’ property is void except as to the vendor’s share. The SC applied it to Francisco Corpuz’s 1934 sale, which occurred after Bernarda Mantile’s death and without liquidation.
• Section 2, Rule 75, Rules of Court — Cited in Ocampo as the current procedure requiring liquidation of the conjugal partnership in testate or intestate proceedings of the deceased spouse; the SC used it to reject the CA’s view that the surviving husband could sell as de facto administrator.