G.R. No. 241774 - Delgado vs. GQ Realty Development Corp.

Petitioner Francisco C. Delgado, originally married to Carmencita Chuidian-Delgado (with whom he had five children), later developed a relationship with Victoria Quirino Gonzales—daughter of former President Elpidio R. Quirino.
Victoria was previously married to Luis Gonzales (deceased in 1984) and had four children with him. Together with her children, she formed a family corporation, respondent GQ Realty Development Corporation, primarily created to hold her properties.
Despite the corporation’s decently capitalized status, petitioner Francisco contended that it lacked the financial heft to engage in the realty business, prompting him to offer assistance.

Acting on Victoria’s suggestion, petitioner Francisco purchased a condominium unit (Unit 12-C, Urdaneta Apartments Condominium, Makati City) using his own funds to enhance the appearance of respondent GQ Realty’s asset base for potential investors.
The title for the subject property was issued under Condominium Certificate of Title No. 9159 in the name of respondent GQ Realty, even though petitioner Francisco occupied the property.
Later, after the marriage between petitioner Francisco and Victoria on June 20, 1987, and subsequent events—including Victoria’s death in 2006—the subject property was transferred from respondent GQ Realty to respondent Rosario (one of Victoria’s children).

Prior to their marriage, petitioner Francisco and Victoria executed an Ante-Nuptial Agreement (dated June 15, 1987) stipulating complete separation of properties so that each party’s assets remained solely theirs.
Petitioner Francisco, alleging an implied trust over the subject property (bought with his funds but registered under respondent GQ Realty), filed a Verified Complaint for Reconveyance, Declaration of Nullity of Sale, and Damages in July 2007 before the RTC of Makati City.
In his Complaint, petitioner Francisco contended that the registration in the name of respondent GQ Realty was solely for the purpose of facilitating Victoria’s business credibility and did not reflect his true interest in the property.

Respondents maintained that GQ Realty is a family holding company intended exclusively to manage Victoria’s assets, not as an avenue for external investment.
They argued that the subject property—bought initially as a gift for Victoria—was properly transferred and that petitioner Francisco’s rights had been waived through the Ante-Nuptial Agreement.
The RTC, after a preliminary hearing (from which petitioner Francisco was absent), ruled that the Complaint had lapsed due to prescription and that petitioner Francisco had effectively waived his claim.
The Court of Appeals (CA) later affirmed the RTC ruling, upholding the dismissal of the case on the ground of waiver (among other affirmative defenses).

Whether petitioner Francisco, by executing the Ante-Nuptial Agreement, unequivocally waived, abandoned, or otherwise extinguished his alleged interest over the subject property.

Whether the subject property, purchased with petitioner Francisco’s funds but registered in the name of respondent GQ Realty, should be considered as having been given as a gift to Victoria.
Whether the evidentiary record—specifically the certificate of title and the terms of the Ante-Nuptial Agreement—is sufficient to bar petitioner Francisco’s claim.