Adalgiza Garcia v. Derly Mascorro

CourtCourt of Appeals of Texas
DecidedMarch 22, 2023
Docket04-21-00394-CV
StatusPublished

This text of Adalgiza Garcia v. Derly Mascorro (Adalgiza Garcia v. Derly Mascorro) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Adalgiza Garcia v. Derly Mascorro, (Tex. Ct. App. 2023).

Opinion

Fourth Court of Appeals San Antonio, Texas MEMORANDUM OPINION

No. 04-21-00394-CV

Adalgiza GARCIA, Appellant

v.

Derly MASCORRO, Appellee

From the County Court at Law, Starr County, Texas Trial Court No. CC-20-170 Honorable Orlando Rodriguez, Judge Presiding

Opinion by: Liza A. Rodriguez, Justice

Sitting: Rebeca C. Martinez, Chief Justice Irene Rios, Justice Liza A. Rodriguez, Justice

Delivered and Filed: March 22, 2023

AFFIRMED IN PART; REVERSED IN PART AND REMANDED

This appeal arises from a final decree of divorce after a bench trial. On appeal, Adalgiza

Garcia argues (1) the trial court erred in characterizing her separate property as community

property; and (2) the trial court erred in failing to order Derly Mascorro to pay her child support,

including retroactive child support. Because we agree the trial court erred in characterizing

Garcia’s separate property as community property, we reverse the portion of the trial court’s final

decree that divides the marital estate. 04-21-00394-CV

BACKGROUND

Garcia and Mascorro married in 1995 and had three children during their marriage. At the

time of the bench trial on October 22, 2020, only one of their children, D.M., was still a minor. A

month later, on November 25, 2000, D.M. turned eighteen years old. The trial court did not sign

the final decree of divorce until June 20, 2021. In the final decree, the trial court found that

Mascorro was not obligated to pay child support, including any retroactive child support requested

by Garcia.

With regard to their assets, the trial court ordered their home to be sold, with 75% of the

net proceeds from the sale being awarded to Mascorro and only 25% of the net proceeds from the

sale being awarded to Garcia. This family home, located at 77 Ramirez Road, sits on two lots. It

is undisputed that these two lots were gifted to both Garcia and Mascorro during their marriage.

That is, on July 19, 2000, by gift deed, Mascorro’s mother transferred the two lots to her “beloved

son and daughter-in-law, Derly A. Mascorro and wife, Adalgiza G. Mascorro.” The family home

was then built on the lots during the marriage. Garcia and Mascorro separated in 2015. Garcia left

the family home and went to live with others. Mascorro remained living in the family home, paying

all the house bills and property taxes.

CHARACTERIZATION OF PROPERTY

In her first issue, Garcia argues the trial court erred in characterizing the family home as

community property. She points out that the two lots on which the family home sits were given to

her and Mascorro, and as gifts, they are separate property. Thus, she argues the trial court erred in

mischaracterizing her separate property as community property. In response, Mascorro contends

that because the family home was built with community funds, the real property can be

recharacterized as community property.

-2- 04-21-00394-CV

“Generally, the characterization of property as separate or community is determined by its

character at inception, often referred to as the ‘inception of title’ doctrine.” Blair v. Blair, 642

S.W.3d 150, 156 (Tex. App.—El Paso 2021, no pet.). Both the Texas Constitution and the Texas

Family Code define separate property as property owned before marriage, or acquired during

marriage by gift, devise, or descent. See TEX. CONST. art. XVI, § 15 (“All property, both real and

personal, of a spouse owned or claimed before marriage, and that acquired afterward by gift, devise

or descent, shall be the separate property of that spouse . . . .”) (emphasis added); TEX. FAM. CODE

3.002 (“Community property consists of the property, other than separate property, acquired by

either spouse during marriage.”); see also Roberts v. Roberts, 402 S.W.3d 833, 838 (Tex. App.—

San Antonio 2013, no pet.) (“Separate property includes property . . . acquired by a spouse during

marriage by gift, devise, or descent.”). Accordingly, it is unconstitutional for a trial court to divest

a party of his or her separate property by awarding any portion of it to another party. Blair, 642

S.W.3d at 156. For this reason, a trial court that improperly divests a party in his or her interest in

separate property commits reversible error as a matter of law without the need of a harm analysis.

Id.

It is undisputed that the two lots on which the family home was built are Garcia’s and

Mascorro’s separate property. Although the family home was built on the separate property during

the marriage, “it is well-established that any improvements made to a spouse’s separate property

during marriage, including the construction of a residence or other buildings thereon, are

considered the spouse’s separate property, and the community receives no ‘right, title or interest

in or to the land.’” Id. at 156-57 (quoting Burton v. Bell, 380 S.W.2d 561, 565 (Tex. 1964)); see

also Kite v. Kite, No. 01-08-00643-CV, 2010 WL 1053014, at *2-4 (Tex. App.—Houston [1st

Dist.] Mar. 11, 2010, no pet.) (holding marital residence built on husband’s separate property was

his separate property). “As the Texas Supreme Court has explained, this is so because the

-3- 04-21-00394-CV

‘improvements become attached to the soil, and cannot, in the nature of things, be divisible in

specie when one of the joint owners has no interest in the land upon which they have been

erected.’” Blair, 642 S.W.3d at 157 (quoting Burton, 380 S.W.2d at 561). Therefore, even though

the family home was built during the marriage, because it was built on separate property, the family

home is also characterized as separate property. See id. We hold the trial court erred in this case

by characterizing the family home and land, commonly known as 77 Ramirez Road, as community

property. See id. Further, by awarding Garcia only 25% of the proceeds from the sale of 77 Ramirez

Road, the trial court erred in divesting her of her separate property.

Having determined that the trial court mischaracterized 77 Ramirez Road as community

property and divested Garcia of her interest in 77 Ramirez Road, we are required to reverse and

remand the issue of property division to the trial court for a retrial on the division of the marital

estate. See Blair, 642 S.W.3d at 161; see also In re Marriage of Case, 28 S.W.3d 154, 161 (Tex.

App.—Texarkana 2000, no pet.) (explaining that when a trial court mischaracterizes separate

property as community property, and the mischaracterized property has value that would have

affected the trial court’s just and right division, the appellate court must remand the entire

community estate to the trial court for a just and right division of the property characterized as

community property). 1

CHILD SUPPORT

In her second issue, Garcia complains the trial court erred in failing to order Mascorro to

pay her child support and retroactive child support. Section 151.001 of the Family Code permits a

trial court to order either or both parents to pay child support. See TEX. FAM. CODE § 151.001.

Additionally, section 154.009 allows a trial court to order a parent to pay retroactive child support

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Related

In Re the Marriage of Case
28 S.W.3d 154 (Court of Appeals of Texas, 2000)
In Re the Marriage of Grossnickle
115 S.W.3d 238 (Court of Appeals of Texas, 2003)
Garza v. Blanton
55 S.W.3d 708 (Court of Appeals of Texas, 2001)
Burton v. Bell
380 S.W.2d 561 (Texas Supreme Court, 1964)
In the Interest of A.L.S., M.B.S., B.P.S. and F.J.S.
338 S.W.3d 59 (Court of Appeals of Texas, 2011)
Martin E. Roberts v. Margaret D. Roberts
402 S.W.3d 833 (Court of Appeals of Texas, 2013)

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