Case Digest (G.R. No. 110115)
Facts:
Rodolfo Tigno and Spouses Edualino and Evelyn Casipit v. Court of Appeals and Eduardo Tigno, G.R. No. 110115, October 08, 1997, Supreme Court Third Division, Panganiban, J., writing for the Court. Petitioners are Rodolfo Tigno and spouses Edualino and Evelyn Casipit; respondents are the Court of Appeals (whose decision is assailed) and Eduardo Tigno (private respondent in the underlying civil action).
In 1980 three adjoining parcels in Lingayen, Pangasinan, owned by members of the Sison family were offered for sale through agent Dominador Cruz. Eduardo Tigno agreed to buy the three parcels at P10,000 each but, because he was based in Makati and intended to mortgage the property at the Philippine National Bank (PNB) for development funds, he instructed that the conveyances be prepared in the name of his brother Rodolfo, who would appear as vendee so he could secure the loan and tend the fishponds. On May 2, 1980 Eduardo made P5,000 downpayments (totaling P15,000) and later issued a P26,000 check that Cruz used to pay the vendors; the deeds of sale executed in May–June 1980 named Rodolfo as vendee, with Cruz and Atty. Modesto Manuel acting as witnesses/attorney who prepared and notarized the deeds.
Years later Rodolfo, without Eduardo’s knowledge or consent, sold 508.56 square meters of one parcel to spouses Edualino and Avelina Casipit on April 29, 1989. Eduardo learned of negotiations in mid-May 1989, sent a letter advising the Casipits to desist, and upon learning the sale had been consummated he filed Civil Case No. 16673 on May 24, 1989 for reconveyance, annulment of document, recovery of possession and damages against Rodolfo and the Casipits. The defendants denied the complaint and asserted that Rodolfo was the owner and that the Casipits bought in good faith for value.
The Regional Trial Court, Branch 38, Lingayen, Pangasinan (Judge Antonio M. Belen) dismissed Eduardo’s complaint and entered judgment for the defendants. The Court of Appeals, Second Division (Kapunan, J., ponente), reversed in CA‑G.R. CV No. 29781 in a Decision promulgated October 15, 1992, declaring Eduardo the true owner, voiding the deed of sale made by Rodolfo to the Casipits, and ordering reconveyance and surrender of possession; a motion for reconsideration was denied in a Resolution promulgated May 5, 1993. Petitioners brought this Rule 45 petition for review on certiorari to the Supreme Court, contesting the CA’s findings on authentication of receipts, ownership,...(Subscriber-Only)
Issues:
- May this Court, in a Rule 45 petition, review the conflicting factual findings between the trial court and the Court of Appeals in this case?
- Did the evidence establish an implied (resulting) trust in favor of Eduardo Tigno, such that Rodolfo held legal title only as trustee under Article 1448 of the Civil Code?
- Were spouses Edualino and Evelyn Casipit purchasers in good faith for valu...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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