G.R. No. 102657 - Nito vs. Court of Appeals

The case involves an appeal by certiorari from a decision of the Court of Appeals, which affirmed the Regional Trial Court’s dismissal of petitioner Feliciano Nito’s complaint for reconveyance of property with damages.
The trial court and Court of Appeals findings of fact were not disputed, and both courts based their decisions on the established factual record.

The former Agricultural Credit Administration (ACA), now the Land Bank, owned three parcels of land in Bangkal, Meycauayan, Bulacan.
Petitioner previously leased a portion of the ACA property. When the lease expired, ACA offered the property for sale through public bidding scheduled on March 22, 1979.

Several individuals, including Conrado Villarama, Renato Carlos, Soledad de Guzman, among others, expressed interest in joining the bidding.
ACA required that interested parties organize themselves as a group and appoint a single representative; the group then appointed private respondent Conrado Villarama.
Each group member contributed money to raise ₱133,000.00, which was deposited as the bid bond.
Although petitioner was included in discussions due to his prior occupation of a portion of the property, he did not contribute to the bid bond and was not a signatory to the group’s formal manifesto.

On March 22, 1979, Villarama became the sole bidder at the public bidding.
The Bids and Awards Committee directed him to negotiate directly with ACA’s Central Office in Manila.
The bid bond was later withdrawn and redeposited as a performance bond.
The group formalized their alliance through a manifesto that, among other matters, authorized Villarama to negotiate the purchase with ACA, although petitioner did not sign this document.

On September 10, 1979, petitioner rendered a cash deposit of ₱10,000.00 to Villarama, intending it as partial payment for the lot allocated to him.
An agreement was reached between Villarama and ACA on a purchase price of ₱1,600,000.00, with the full amount required on or before March 16, 1982; failure to comply would result in forfeiture of the cash deposit as liquidated damages.
Prior to the payment deadline, the group convened and, via their counsel Atty. Irineo Guardiano, sent petitioner a letter on March 8, 1982, demanding full payment for the lot he was to purchase and warning that non-payment would be construed as a lack of interest.
Although other group members paid their respective shares on March 16, 1982, petitioner neither attended the meeting nor remitted payment through the group, instead tendering a check for ₱125,000.00 directly to ACA, which ACA refused and instructed him to coordinate with Villarama.

Knowing of petitioner’s delay, the group—through Villarama—asked private respondent Candido Milan to provide ₱125,000.00 for petitioner’s allocated lot if petitioner failed to pay.
Milan accepted the proposal, and on March 17, 1982, after petitioner’s absence until 5:00 P.M., the group used Milan’s contribution along with other funds to complete the payment to ACA.
ACA subsequently issued the Deed of Sale to Villarama who then arranged the resurvey and issuance of individual deeds of sale and certificates of title to the buyers.

Petitioner charged fraud and breach of trust, claiming that his ₱10,000.00 deposit constituted the creation of a trustee relationship under Article 1452 of the Civil Code.
He argued that by virtue of such deposit he became a co-purchaser or co-owner of the property, so his non-payment of the full share (₱137,705.00 or ₱135,000.00 as argued) should not forfeit his right as co-purchaser.
He contended that the group's actions, intended to protect the collective interest, should not allow his individual share to be given away to Milan.
Petitioner further pointed to the requirement under Article 1452 that when persons agree to purchase property and the title is taken in one name for the benefit of all, an implied trust arises in favor of the others proportionate to their interests.

Whether petitioner’s deposit of ₱10,000.00 to Villarama established a trustee relationship under Article 1452 of the Civil Code of the Philippines, thereby entitling him to a share as a co-purchaser.

Did the deposit and his participation in discussions, despite not joining the formal group or signing the manifesto, suffice to create an implied trust?
Is mere deposit evidence of his intention to be part of a common purchase scheme on equal footing with other group members?

Whether petitioner’s non-payment of his full share beyond his partial deposit, in light of his insistence on obtaining a lot with a 32-meter frontage, constitutes a waiver of his right to purchase the property.

Was petitioner’s direct attempt to tender payment to ACA proper, given that the formal group arrangement required payments through Villarama?
Can the group’s decision to secure alternative funds (from Milan) be justified as a consequence of petitioner’s failure to meet the agreed deadline?

Whether the established facts and conduct of petitioner negate the applicability of Article 1452 in creating an implied trust that would benefit him as a co-owner.