Facts:Miguel Palang contracted his first marriage with Carlina (or Cornelia) on July 16,1949. A few months after the wedding, in October 1949, he left for work in Hawaii. Miguel and Carlinas only child, Herminia Palang, was born on May 12, 1950. During his visit in 1964to the Philippines, he stayed with his brother in Zambales. The trial court found that as earlyas 1957, Miguel had attempted to divorce Carlina in Hawaii. When he returned for good in1972, Miguel refused to stay with Carlina but stayed alone in a house in Pozorrubio,Pangasinan. On July 15, 1973, 63 yr old Miguel contracted with second marriage with 19 yrold Erlinda Agapay. Two months earlier, Miguel and Erlinda jointly purchased a parcel of agricultural land located at San Felipe, Binalonan Pangasinan. A house and lot in Binalonan,Pangasinan was also purchased by Erlinda as sole vendee. On October 1975, Miguel andCornelia Palang executed a deed of donation as a form of compromise agreement. Theparties agreed to donate their conjugal property to their only child, Herminia Palang. Migueland Erlinda had a son, Kristopher A. Palang. In 1979, Miguel and Erlinda were convicted of Concubinage upon Carlinas complaint. Two years later, Miguel died.On July 11, 1979, Carlina Palang and her daughter Herminia filed an action forrecovery of ownership and possession of the Riceland and house and lot both located atBinalonan, Pangasinan allegedly purchased by Miguel during his cohabitation with ErlindaAgapay. The RTC dismissed the case and ruled in favour of Agapay. On appeal, the respondent court reversed the trial courts decision and declared Carlina and Herminia Palang the owners of the properties in question. Issue(s):1. Whether or not the court erred in granting the ownership of the two parcels of land to Carlina and Herminia Palang?2. Whether or not the court erred in not declaring Kristopher Palang as Miguelsillegitimate son and thus entitled to inherit Miguels estate? 3.
Whether or not Kristopher Palang should be considered as party-defendant inthe
civil case? Decision:1. No. Under Art 148 of the Family Code of the Philippines, only properties acquiredby both of the parties through their actual joint contribution of money, property,or industry shall be owned by them in common in proportion to their respectivecontributions. It must be stressed that actual contribution is required in this