Short answer. Yes, if conjugal funds remain. Family Code Article 129 provides that the loss of movables used for the family's benefit, even from a fortuitous event like fire, is paid to the owning spouse from the conjugal funds, if any, unless that spouse was already indemnified from some other source.
What the law says
the loss or deterioration of movables used for the benefit of the family, belonging to either spouse, even due to fortuitous event, shall be paid to said spouse from the conjugal funds, if any
Family Code, Article 129 — How the Conjugal Partnership Is Liquidated. Read the full provision →
The specific rule on lost family movables
Article 129 sets out the step-by-step procedure for liquidating a conjugal partnership, and one of its numbered steps addresses exactly your situation. It provides that unless the owner had been indemnified from whatever source, the loss or deterioration of movables used for the benefit of the family, belonging to either spouse, even due to fortuitous event, shall be paid to said spouse from the conjugal funds, if any. Appliances used by the household are squarely the kind of movables this provision describes, and a fire is exactly the sort of fortuitous event the clause anticipates.
Why fault does not matter here
Because the article specifically says even due to fortuitous event, the reimbursement does not depend on anyone being at fault for the destruction. A fire that nobody caused deliberately or negligently still triggers this rule, so long as the appliances were used for the family's benefit and belonged to one of the spouses. It also does not matter which spouse technically owned the appliances; the article extends this reimbursement to movables belonging to either spouse, as long as they served the family's use.
The two conditions that limit the payout
Two limits are built into the text. First, the phrase if any attached to conjugal funds means this reimbursement is capped by what conjugal funds actually exist at liquidation; if there are none left after the other steps in the liquidation process, there is nothing to pay from under this specific provision. Second, the opening clause, unless the owner had been indemnified from whatever source, means that if the loss was already covered, for instance through an insurance payout, the spouse is not paid twice for the same loss out of the conjugal funds.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Brigido B. Quia vs. Rita C. Quiao, et al, G.R. No. 176556, July 4, 2012 — read the decision on LawPhil →
- Ceferino S. Cabreza, Jr., et al. vs. Amparo Robles Cabreza, G.R. No. 181962, January 16, 2012 — read the decision on LawPhil →
- Marietta N. Barrido vs. Leonardo V. Nonato, G.R. No. 176492, October 20, 2014 — read the decision on LawPhil →
- Amparo Robles Cabreza vs. Ceferino S. Cabreza Jr., et al, G.R. No. 171260, September 11, 2009 — read the decision on LawPhil →