Case Digest (G.R. No. 196023) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Jose Juan Tong, et al. vs. Go Tiat Kun, et al. (G.R. No. 196023, April 21, 2014), the petitioners, nine of the ten heirs of Spouses Juan Tong and Sy Un, and the heirs of their deceased brother Luis Juan Tong, Sr., sought nullification of titles and deeds covering Lot 998-A, now covered by TCT No. 134082. In 1957, Juan Tong purchased Lot 998 for the family lumber business but, being a Chinese citizen, caused the title to be issued in the name of his only Filipino child, Luis, Sr. After Luis, Sr.’s death in 1981, his heirs (respondents) executed an extrajudicial settlement in 1982 and secured TCT No. T-60231. They later subdivided the lot into Lots 998-A and 998-B (TCT Nos. 97068 and T-96216). Lot 998-B was sold and reconveyed to the petitioners through prior litigation, while Lot 998-A was sold among respondents and titled under TCT No. 134082 in 2001. In 2005, the petitioners filed Civil Case No. 05-28626 for nullification of titles, alleging an implied resulting trust in the Case Digest (G.R. No. 196023) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Property
- Petitioners: Nine children (and their descendants) of Spouses Juan Tong and Sy Un, claiming Lot 998-A (2,525 sqm) now under TCT No. 134082.
- Respondents: Heirs of the late Luis Juan Tong, Sr. (the tenth child), including his spouse Go Tiat Kun and their children.
- Acquisition and Initial Registration
- 1957: Juan Tong (a Chinese citizen) finances the P 55,000 purchase of Lot 998 but registers title under his only Filipino son, Luis Sr., to circumvent citizenship restrictions.
- The lot serves as stockyard for “Juan Tong Lumber” (later corporation in 1978) and remains undivided and in family use.
- Succession, Subdivision, and Prior Litigation
- 1981: Luis Sr. dies. Respondents extrajudicially settle his estate (approved 1982), securing TCT No. T-60231.
- 1992 subdivision: Lot 998-A to Go Tiat Kun and her children (TCT No. 97068), Lot 998-B to Luis Jr. (TCT No. T-96216).
- Lot 998-B sold to FRDC then VGCC; petitioners successfully annulled the sale in Civil Case No. 22730, reconveyed Lot 998-B.
- 2001: Go Tiat Kun sells undivided interest in Lot 998-A to her children, producing TCT No. 134082.
- 2005: Petitioners file Civil Case No. 05-28626 for Nullification of Titles, Deeds of Extra-Judicial Settlement and Sale, and Damages over Lot 998-A.
- Trial and Appellate Proceedings
- RTC (2009): Finds implied resulting trust in favor of petitioners; nullifies respondents’ deeds and titles; orders reconveyance and damages.
- CA (2010): Reverses RTC, dismisses complaint—rules express trust requires writing, implied trust terminated by death and prescribed, presumption of donation, laches and estoppel.
- SC Grant of Review: Petitioners elevate the case by petition for review under Rule 45.
Issues:
- Whether an implied resulting trust arose when Lot 998 was registered in Luis Sr.’s name despite being purchased with Juan Tong’s funds.
- Whether parol evidence is admissible to prove the existence of the trust.
- Whether the petitioners’ action is barred by prescription, estoppel, or laches.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)