G.R. No. 858 - Martinez vs. Martinez

Plaintiff-Appellee: Francisco Martinez, father of the defendant
Defendant-Appellant: Pedro Martinez, son of the plaintiff
Property in dispute: Two vessels, the steamer *Balayan* and the coasting vessel *Ogono*

Titles to both vessels were registered in the name of the defendant (Pedro Martinez).
Registration is prima facie evidence of ownership and legal title.

Plaintiff claims ownership on the basis that he furnished the money to purchase the two vessels.
No written contract or agreement between father and son was found relating to ownership or agency.
Plaintiff alleged that the defendant acted as his agent in the purchase, but this was denied and unsupported by findings.
The son (defendant) was of legal age; therefore, provisions applied only to minors did not apply.
The *Balayan* was bought using funds from the conjugal partnership (father’s money), and the title was registered in the son’s name upon the father’s direction.
The *Ogono* was also purchased with the money of the father, but his involvement in the purchase is less clear.

The trial court found the father (plaintiff) to be the true owner of the vessels despite the registration in the son’s name.
The son’s ownership based on registry was held insufficient against the fact that the father paid for the vessels and exercised acts of ownership.
There was no finding that the son held the property as agent or trustee for the father.
A letter written by the defendant to plaintiff asking if he wished to sell *Balayan* was presented but not included in the court's findings.

The Supreme Court discussed that ownership must be established under Article 609 of the Civil Code and that mere payment of purchase money does not vest ownership in the payer absent legal transfer.
The Court noted that under Philippine law, no legal or equitable title was automatically transferred to the plaintiff by payment alone.
The law did not recognize a resulting trust or constructive trust on these facts.
The Court further stressed that the father's acts of ownership do not transfer legal title from the son.
The Court granted a new trial, reversing the lower court’s decision.

Justice Cooper dissented, arguing the lower court’s finding of plaintiff’s ownership was an ultimate fact supported by sufficient evidence.
He held that registration is merely evidentiary, not conclusive, and that acts of ownership and payment by the father support ownership in the father.
Cited rules on review of factual findings and ultimate facts versus evidentiary facts.
Emphasized the relationship of father-son and operation of agency or fiduciary duties by the son.
The son’s management of the vessels under a general power of attorney confirmed the father's ownership.

Whether the registration of the vessels in the name of the defendant (son) conclusively establishes his ownership.
Whether payment of the purchase price by the plaintiff (father) creates ownership or any legal interest in the vessels absent a contract, donation, or other legal means of title transfer under Philippine law.
Whether acts of ownership by the plaintiff and alleged agency relationship between plaintiff and defendant affect the ownership of the vessels.
Whether the lower court’s factual findings are sufficient and binding on appeal without a motion for new trial or exception.