Case Digest (G.R. No. 175073)
Case Digest (G.R. No. 175073)
Facts:
Estate of Margarita D. Cabacungan, represented by Luz Laigo-Ali v. Marilou Laigo, Pedro Roy Laigo, Stella Balagot and Spouses Mario B. Campos and Julia S. Campos, G.R. No. 175073, August 15, 2011, Supreme Court Third Division, Peralta, J., writing for the Court.Petitioner (the Estate, substituted for Margarita Cabacungan) sued respondents Marilou Laigo, Pedro Roy Laigo, Estella Balagot (later dropped), and the spouses Mario and Julia Campos for annulment of sales, recovery of ownership and possession, cancellation of tax declarations, and damages. Margarita owned three parcels of unregistered land in Bauang, La Union, each covered by tax declarations in her name. In 1968, to help her son Roberto Laigo, Jr. secure a U.S. visa, Margarita executed an Affidavit of Transfer transferring the tax declarations to Roberto; Roberto left for the U.S. and returned shortly thereafter.
Roberto subsequently sold one lot in July 1990 to the Spouses Campos and, in August 1992, sold the two remaining lots to respondents Marilou and Pedro for modest sums. Margarita allegedly did not know of these sales until Roberto’s wake in August 1995 when Pedro informed her. In February 1996 Margarita (through her daughter Luz) filed the instant complaint alleging that the 1968 transfer was only an accommodation to support Roberto’s visa application and thus created an implied trust; Roberto had no right to sell the properties and his sales were fictitious and fraudulent.
Respondents pleaded, inter alia, that they were innocent purchasers for value and in good faith; that Margarita’s claim was barred by prescription and laches; and that any cause of action accrued in 1968 when the Affidavit of Transfer was executed (creating an implied trust whose ten-year prescriptive period had long run). Before trial, Margarita and the Spouses Campos settled their dispute by compromise on February 3, 1999; Margarita died two days later and the Estate was substituted. The trial court approved the compromise (Partial Decision, Feb. 8, 1999) and dismissed the case against the Camposes; trial continued against Pedro and Marilou.
On July 2, 2001 the Regional Trial Court, Branch 33, La Union, dismissed the complaint as to Pedro and Marilou, finding that the 1968 Affidavit of Transfer operated as a transfer (not an express trust), that at most an implied or constructive trust arose, and that Margarita’s long inaction constituted laches; the court also held the ten-year prescription for reconveyance based on an implied trust had run and that mere inadequacy of price did not vitiate consent. Petitioner appealed.
On October 13, 2006 the Court of Appeals in CA‑G.R. CV No. 72371 affirmed the trial court’s dismissal. The CA agreed there was no proof of an express trust and, while entertaining that an implied trust might be alleged, held Margarita’s action was barred by laches and prescription, and treated respondents as buyers in good faith for purposes of the unregistered-land sales dispute. Petitioner sought review by the Supreme Court via a Petition for Review under Rule 45.
Issues:
- Did the evidence establish an implied trust (resulting or constructive) between Margarita and Roberto with respect to the three parcels transferred by the 1968 Affidavit of Transfer?
- Were the respondents protected as innocent purchasers for value of unregistered land such that they cannot be compelled to reconvey?
- Was petitioner’s action barred by prescription or laches?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)