Case Digest (G.R. No. 84888)
Facts:
Spouses Ricardo and Milagros Huang v. Court of Appeals, Judge Pedro N. Laggui, Presiding Judge, RTC, Makati, Br. 60, and Spouses Dolores and Aniceto Sandoval, G.R. No. 108525, September 13, 1994, First Division, Bellosillo, J., writing for the Court.In 1965 Dolores Sandoval purchased two adjacent lots in Dasmariñas Village but, being advised that the subdivision's policy barred the acquisition of two lots by a single person, caused one lot (Lot 20) to be registered in the name of her brother’s wife’s husband, Ricardo Huang (TCT No. 204783), while Lot 21 was registered in her own name. Dolores financed the acquisition and later paid for substantial improvements (house, swimming pool, fence) and also paid off an SSS loan on Lot 20. The Huangs were said to hold title in trust for Dolores. On 19 March 1968 Dolores secured from the Huangs a deed of absolute sale with assumption of mortgage in her favor.
Tension arose when the Huangs leased the house on Lot 20 on 15 March 1980 without Dolores’s permission and thereafter began to challenge the Sandovals’ ownership. After unsuccessful barangay conciliation (Lupong Tagapayapa certification dated 16 December 1980), the Huangs filed Civil Case No. 39702 in the Court of First Instance of Rizal on 22 December 1980 seeking nullity of the deed and/or quieting of title. Dolores filed Civil Case No. 40288 on 19 February 1981 against the Huangs and the SSS seeking, among other reliefs, the surrender of the owner’s copy of TCT No. 204783 and registration of the deed in her name. The two cases were consolidated and tried together.
The trial court (Court of First Instance/Regional Trial Court, Makati, Br. 60) found that Dolores paid for Lot 20 and its improvements, that the Huangs held title in trust for her, and that the deed of sale with assumption of mortgage was valid; it dismissed the Huangs’ complaint and ordered, inter alia, annotation/cancellation and issuance of title in Dolores’s name, delivery of rentals, exemplary damages and attorney’s fees. The trial court denied the Huangs’ motion for reconsideration on 26 July 1989. The Court of Appeals affirmed the trial court’s decision (decision dated 28 September 1992) and denied the Huangs’ motion for reconsideration (resolution da...(Subscriber-Only)
Issues:
- Was the Court’s finding that a resulting (implied) trust existed between the Huangs and Dolores supported by substantial evidence?
- Was Dolores’s action to compel reconveyance barred by prescription?
- Could the deed of sale with assumption of mortgage be treated as an equitable mortgage so as to render parol evidence inad...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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