Pugeda v.

Trias
G.R. No. L-16925 July 24, 1962 Labrador J.
VII-4C-1 Requisites Created by: Irene
Plaintiff-Appellee Defendants-Appellants
FABIAN PUGEDA RAFAEL TRIAS, MIGUEL TRIAS, SOLEDAD TRIAS,
assisted by her husband ANGEL SANCHEZ, CLARA
TRIAS, assisted by her husband VICTORIANO
SALVADOR, GABRIEL TRIAS, minors ROMULO
VINIEGRA, GLORIA VINIEGRA and FERNANDO
VINIEGRA, JR., assisted by guardian-ad-litem,
TEOFILO PUGEDA and VIRGINIA PUGEDA, assisted
by her husband RAMON PORTUGAL, defendants-
appellants
Recit Ready Summary
The motion for reconsideration of the decision rendered by the Court on the lot paid by the widow of
Miguel Trias, which was not fully paid by the time of his death and was only paid by the widow, was
contended that based on the Friar Lands Act, in reference to the certificate of sale transferred to the
wife, the lot should be an exclusive paraphernal property. However, the court ruled on the basis that
the provision of the Friar Lands Act is merely an administrative device designed to facilitate the
documentation of the transaction and the collection of installments; it does not produce the
effect of destroying the character as conjugal property of the lands purchased according to the
provision of the Civil Code to the effect that properties acquired by husband and wife are conjugal
properties (Art. 1401, Civil Code of Spain). Thus, the said lands, notwithstanding a certificate of
sale, continue to be the conjugal property of her deceased husband and herself.
Facts
1. The resolution concerns a motion for the reconsideration of the decision rendered by
the Court.
2. The lots not fully paid for at the time of the death of Miguel Trias, by provision of the
Friar Lands Act (Act No. 1120), subsequently transferred to the widow's name and later
paid for by her out of the proceeds of the fruits of the lands purchased and for which
titles were issued in the name of the widow.

Issues Ruling
 WON the lot that is not fully paid at the No
time of death of Miguel Trias and was
proceeded to be paid by the widow after
will be considered as her exclusive
paraphernal property and not conjugal
properties of her deceased husband and
herself
Rationale/Analysis/Legal Basis
1. There is a rule that upon the issuance of a certificate of sale of the husband of a lot in
a friar lands estate, purchased by the Government from the friars, the land becomes the
property of the husband and the wife, and the fact that the certificate of sale is
thereafter transferred to the wife does not change the status of the property so purchases
as conjugal property of the deceased husband and wife.

The reason for this ruling is the provision of the Civil Code to the effect that properties
acquired by husband and wife are conjugal properties. (Art. 1401, Civil Code of Spain).
The provision of the Friar Lands Act to the effect that upon the death of the husband
the certificate of sale is transferred to the name of the wife is merely an administrative
device designed to facilitate the documentation of the transaction and the collection of
installments; it does not produce the effect of destroying the character as conjugal
property of the lands purchased.

Disposition
The motion for reconsideration is hereby denied and the judgment rendered declared final.