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Philippine National Bank v. Quintos: Estate Partition Dispute

Crispulo Javillo was married twice, first to Ramona Levis with whom he had five children. After Ramona's death, he married Rosario Oñas with whom he had four more children. After Crispulo's death, his estate entered into partition proceedings. Rosario Oñas appealed, arguing that the court erred in finding that properties acquired in the second marriage were from the first marriage and in approving the partition that did not include all of Crispulo's properties. The Supreme Court held that the conjugal partnership is liable for obligations during marriage and the spouses' private properties may be liable as well unless otherwise stipulated.

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165 views1 page

Philippine National Bank v. Quintos: Estate Partition Dispute

Crispulo Javillo was married twice, first to Ramona Levis with whom he had five children. After Ramona's death, he married Rosario Oñas with whom he had four more children. After Crispulo's death, his estate entered into partition proceedings. Rosario Oñas appealed, arguing that the court erred in finding that properties acquired in the second marriage were from the first marriage and in approving the partition that did not include all of Crispulo's properties. The Supreme Court held that the conjugal partnership is liable for obligations during marriage and the spouses' private properties may be liable as well unless otherwise stipulated.

Uploaded by

MichaelVillalon
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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The Philippine National Bank v. Quintos, G.R. No.

L-22382, 6 October, 1924

FACTS:
Crispulo Javillo contracted two marriages, the first with Ramona Levis, to this marriage,
five children were born; Consolacion, Mercedes, Caridad, Soledad, and Jose. After the death of
Ramona Levis, Crispulo married Rosario Oñas, to this marriage, four children were born;
Joaquin, Ana, Bernardo, and Porillana. Rosario Oñas is the appellant in this case. The parties
concluded an agreement related to the property acquired during the first and second marriages.
When Crispulo Javillo died, a petition was filed in the CFI that an administrator of this
estate be appointed, the second project of partition is the one now on appeal in this case. The
appellant alleges that the lower court committed error in its decision. Thus, this appeal from an
order of the CFI.

ISSUE:
Whether or not the court erred in holding that all the properties acquired during the
second marriage were acquired with the products of the properties of the first marriage and in
approving the manner of distributing the estates among the heirs of the first and second
marriages as indicated in the project of partition now in question.
Whether or not the court erred in approving the second project of partition
notwithstanding that the same did not include all the properties of the deceased.

HELD:
The conjugal partnership is liable for obligations contracted during marriage, and in
default of conjugal property, the spouses are jointly liable therefor with their private properties,
unless by express stipulation, they shall have bound themselves solidarily.

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