Title
Spouses Trinidad vs. Imson
Case
G.R. No. 197728
Decision Date
Sep 16, 2015
Spouses Trinidad claimed ownership of a condominium unit, alleging unpaid rent by tenant Imson. Imson countered, asserting she paid for the unit, held in trust by Armando. Courts ruled in her favor, finding implied trust and sufficient evidence of ownership, overriding notarized deeds.

Case Digest (G.R. No. 206484)
Expanded Legal Reasoning Model

Facts:

  • Parties and Background
    • Petitioners, Spouses Armando and Lorna Trinidad, filed a complaint for ejectment against respondent, Dona Marie Glenn Imson.
    • The dispute centers on a condominium unit, Unit 2203 at AIC Gold Tower, Emerald Avenue, Ortigas Center, Pasig City.
    • Petitioners allege ownership based on:
      • A Deed of Assignment and Transfer of Rights dated June 13, 2002.
      • A subsequent Deed of Absolute Sale dated July 13, 2007 executed in Armando’s name.
    • The underlying claim arose when the petitioners bought the unit from three Indian nationals, who were originally bound by an agreement with AIC Realty Corporation, although these sellers had not fully paid for the property at the time of petitioners’ purchase.
  • Transaction and Lease Background
    • At the time of the purchase, the condominium unit was under lease by respondent:
      • The lease contract with the (original) owners ran from April 1, 2002 to March 1, 2003.
      • Petitioners acknowledged and respected this lease agreement.
    • Issues arose when respondent, having remained in possession beyond the lease term:
      • Failed to remit or consign monthly rental payments.
      • Accumulated rental arrears amounting to P2,130,000.00.
    • Petitioners attempted amicable settlement by sending a letter of demand, which was ignored by respondent.
  • Respondent’s Position and Evidence Submitted
    • In her Answer with Compulsory Counterclaims, respondent contended:
      • She had originally entered into a valid lease with the former owners of the condominium unit.
      • In June 2002, she decided to purchase the unit herself.
      • For convenience and due to personal circumstances (such as annulment proceedings), she opted to have Armando Trinidad purchase and register the property in his name, with the understanding that the property was fundamentally hers.
    • Respondent’s evidence to assert ownership included:
      • Payment records comprising nine personal checks drawn between October 2002 and June 2003 for the purchase price.
      • Acknowledgment Receipt from the former owners evidencing receipt of these payments.
      • Real Property Tax Receipts, certification from AIC Golden Tower Condominium, and other bills (association dues, water bills, common area real estate tax, building insurance) paid by respondent.
      • An affidavit from the former owners confirming that Armando was to hold the property on behalf of respondent.
    • Respondent maintained her open, public, and uninterrupted possession of the property from April 2002 until the filing of her Answer.
  • Procedural History and Prior Court Rulings
    • The case initiated with the filing of the ejectment complaint before the Metropolitan Trial Court (MeTC) of Pasig City on August 17, 2007.
      • The MeTC rendered a Decision dismissing petitioners’ complaint and ordering them to pay respondent P250,000.00 as attorney’s fees and costs.
      • The MeTC found that respondent was the true owner, basing its conclusion on the overall contractual arrangement.
    • Petitioners appealed the MeTC decision:
      • The Regional Trial Court (RTC) of Pasig City reversed the MeTC Decision on June 19, 2009, ordering respondent and persons claiming under her to vacate the unit and pay rental arrears from July 13, 2007.
      • The RTC held that the notarized documents (Deed of Assignment/Transfer of Rights and Deed of Absolute Sale) proved petitioners’ claim of title.
    • Respondent elevated the case to the Court of Appeals (CA):
      • On December 22, 2010, the CA reversed the RTC decision by setting aside the judgment in favor of petitioners.
      • The CA, evaluating all evidence, ruled that respondent’s documentary and testimonial proof of payment and other acts of ownership outweighed petitioners’ evidence.
      • Petitioners’ subsequent Motion for Reconsideration was denied in a CA Resolution issued on June 23, 2011.
    • The instant petition for review on certiorari was then filed, raising issues regarding the sufficiency and interpretation of the evidence on ownership and possession.

Issues:

  • Sufficiency of Respondent’s Evidence
    • Whether the documentary evidence (personal checks, receipts, tax and utility payments, and affidavits) tendered by respondent is sufficient to establish her ownership of the condominium unit.
    • Whether these evidences are enough to overcome the prima facie presumption created by the notarized Deed of Assignment and Transfer of Rights and the Deed of Absolute Sale.
  • Proper Interpretation of the Documents
    • Whether the contents of the Deed of Assignment and Transfer of Rights and the Deed of Absolute Sale truly reflect the parties’ intentions concerning the ownership of the subject property.
    • Whether the doctrine on parole evidence, with its recognized exceptions, permits respondent to introduce extrinsic evidence to prove the true intent of the parties.
  • Existence of an Implied (Resulting) Trust
    • Whether the circumstances and the evidence presented by respondent establish the existence of an implied trust wherein respondent is the beneficial owner despite the registration of title in Armando’s name.
    • Whether respondent’s actions, including her consistent payment for the property and taking possession, suffice to prove that she furnished the valuable consideration, thereby giving rise to a purchase money resulting trust.
  • Ownership versus Possession
    • Whether the issue of ownership, as established by documents and evidence, is final and binding or merely provisional and relevant for the purpose of vindicating possession.
    • How the relationship between possession and title is to be determined, particularly in view of the landlord-tenant dynamics and subsequent transactions.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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