Case Digest (G.R. No. 196023)
Facts:
Jose Juan Tong, et al. v. Go Tiat Kun, et al., G.R. No. 196023, April 21, 2014, the Supreme Court First Division, Reyes, J., writing for the Court.The petitioners are nine of the ten children of Spouses Juan Tong and Sy Un (and descendants of the tenth, the late Luis Juan Tong, Sr.), who assailed the respondents—survivors and heirs of Luis, Sr.—over ownership of Lot No. 998 (subsequently subdivided into Lots 998‑A and 998‑B), now covered by Transfer Certificate of Title No. T‑134082 (Lot 998‑A). The petitioners alleged that although title was placed in the name of Luis, Sr., he held it in trust for the family and that the respondents’ extra‑judicial settlements, sales and titles were null and void.
In 1957 Juan Tong purchased Lot 998 for use as the family lumber business’s stockyard but, being a Chinese citizen, caused title to be registered in the name of his Filipino son, Luis, Sr. In 1981 Luis, Sr. died; in 1982 the respondents executed an Extra‑Judicial Settlement adjudicating Lot 998 to themselves, leading to cancellation of TCT No. 10346 and issuance of TCT No. T‑60231 (1982). In 1992 the lot was subdivided into Lots 998‑A (TCT No. 97068/T‑134082) and 998‑B (TCT No. T‑96216). After petitioners learned of dispositions affecting Lot 998‑B, they successfully litigated reconveyance of Lot 998‑B in Civil Case No. 22730—the trial court, the Court of Appeals (CA), and this Court ruled in their favor, and Lot 998‑B was reconveyed to them.
On August 2, 2005 petitioners filed Civil Case No. 05‑28626 against the respondents for Nullification of Titles and Deeds of Extra‑Judicial Settlement and Sale and Damages as to Lot 998‑A. The Regional Trial Court (RTC), Branch 37, Iloilo City, in a Decision dated May 21, 2009, found an implied resulting trust in favor of the petitioners, declared the respondents’ deeds and titles null and void, awarded reconveyance of Lot 998‑A and damages, and dismissed the respondents’ counterclaim.
The CA, in a Decision dated October 28, 2010 (and a Resolution denying reconsideration dated March 3, 2011), reversed and set aside the RTC, dismissed the complaint for lack of merit, held that an express trust had been created and thus required written proof, found prescription applicable because the resulting trust terminated at the death of Luis, Sr. and became constructive, invoked ...(Subscriber-Only)
Issues:
- Was there an implied resulting trust constituted over Lot 998 when Juan Tong purchased the property and registered it in the name of Luis, Sr.?
- May parol evidence be used to prove the establishment of an implied resulting trust?
- Were the petitioners’ actions barred by prescript...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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