Non-financial contributions including homemaking, gardening, and property maintenance are relevant to the imposition and quantification of a constructive trust in de facto relationship property disputes. A partner's failure to dispute the other's assertion of sole ownership during the relationship does not prevent a later constructive trust claim. A common intention or estoppel is not a necessary foundation for a constructive trust under Baumgartner principles. Appellate courts will not interfere with apportionment of beneficial interests unless the apportionment adopted cannot be defended.
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