RIVERA V. VILLANUEVA (CIVIL)

The cohabitation of Villanueva and Gonzales from 1927-1963 was adulterous, their property relations during those 36 years were not governed by Article 144 of the Civil Code, which applies only if the couple living together is not in any way incapacitated from getting married.

According to the doctrine laid down by Juaniza Agapay v. Palang, we expounded on this doctrine that in such relationship, it is necessary for each of the partners to be able to lay claim to any portion of it. Presumptions of co-ownership and equal contribution do not apply.