G.R. No. 110115 - Tigno vs. Court of Appeals

Petitioners: Petitioner Rodolfo Tigno and spouses (Edualino and Evelyn Casipit) challenged the decisions of the Court of Appeals and the claim of Eduardo Tigno.
Private Respondent: Eduardo Tigno, who later established that he was the true purchaser and owner of the disputed lands.

In January 1980, Bienvenido Sison, Remedios Sison, and the heirs of Isaac Sison appointed Dominador Cruz as their agent to sell three adjoining parcels of land in Lingayen, Pangasinan.
The properties, consisting of fishponds and a piece of unirrigated rice (later converted into a fishpond), were described with detailed boundaries and areas, as evidenced by various exhibits.

Sometime in April 1980, Rodolfo Tigno learned of the sale and instructed Cruz to offer the properties to his brother, Eduardo Tigno.
Meetings were held in a Makati office where Eduardo, despite his initial reluctance, agreed to purchase the lands at an agreed price of Ten Thousand Pesos per parcel.
On May 2, 1980, a meeting took place at Atty. Modesto Manuel’s residence to prepare the deeds of sale. Issues arose regarding the availability of tax declarations, a proper Special Power of Attorney from one of the heirs, and an existing mortgage on one of the properties.

Although no deed was executed on the initial meeting day, the vendors still requested a 50% down payment, which Eduardo provided (a total of P15,000.00, at P5,000.00 per parcel).
Eduardo Tigno later instructed that the deeds be prepared with Rodolfo Tigno listed as the vendee so that the latter could mortgage the properties at the Philippine National Bank (PNB) to obtain funds for developing the fishponds.
Deeds of sale were eventually prepared on May 6, May 12, and June 12, 1980, by Atty. Manuel, with Dominador Cruz witnessing the transactions and subsequent payments, including a later payment via a check of P26,000.00.

On April 29, 1989, without Eduardo Tigno’s knowledge or consent, Rodolfo Tigno sold 508.56 square meters of the property to spouses Edualino and Avelina Casipit.
Eduardo, upon learning of this unauthorized sale, sent a letter on May 16, 1989, urging the Casipits to desist from the transaction, followed by a personal confrontation when he later discovered that the sale had already been consummated.
Consequently, Eduardo Tigno filed Civil Case No. 16673 on May 24, 1989, for reconveyance, annulment of the document, recovery of possession, and damages, asserting that he was the rightful owner based on the implied trust.

The trial court initially dismissed Eduardo’s complaint, ruling in favor of the defendants.
The Court of Appeals reversed the trial court’s decision, recognizing that an implied trust had been created between the Tigno brothers and that Eduardo was the true owner of the contested lands.
Petitioners then elevated the issue to the Supreme Court through a petition for review under Rule 45.

Whether the evidence on record establishes the existence of an implied (resulting) trust between Petitioner Rodolfo Tigno and Private Respondent Eduardo Tigno regarding the contested lands.

Whether spouses Casipit, as purchasers in good faith and for valuable consideration, can acquire valid ownership of the property despite the findings of an implied trust and the irregularities in the sale.

Whether the receipts, deeds of sale, and tax declarations (all in Rodolfo Tigno’s name) suffice to prove him as the true owner, or if they merely reflect a fiduciary arrangement.
The role of oral evidence and witness testimonies in substantiating the oral instructions and understanding between Eduardo and Rodolfo Tigno regarding the true purchaser.