Case Summary (G.R. No. 233775)
Factual Background
Respondent alleged that petitioner introduced to him two parcels of land in Barrio Pineda, Pasig City, and that, at his insistence, petitioner agreed to pose as buyer because the vendor preferred to deal with her; respondent claimed that he furnished the full purchase price amounting to P15,000,000, and that petitioner agreed to hold title in trust and to reconvey the properties to him. Respondent asserted that, after payment, petitioner registered the properties in her name under TCT Nos. PT-111136 and PT-111137 pursuant to a Deed of Absolute Sale dated May 25, 1999, while respondent immediately entered into actual possession, introduced renovations costing P9,000,000, paid real property taxes for thirteen years, and paid homeowner association dues. Petitioner countered that she purchased the properties under a Pacto de Retro and subsequently under a Deed of Absolute Sale in her favor, that respondent volunteered to finance renovations due to their special relationship, that respondent and his family occupied the house by her leave, and that respondent later surreptitiously filed an adverse claim and initiated ejectment and reconveyance proceedings.
Trial Court Proceedings
The Regional Trial Court rendered its Decision on November 5, 2010 and declared respondent as the absolute and rightful owner of the parcels covered by TCT Nos. PT-111136 and PT-111137. The RTC ordered petitioner to execute a Deed of Reconveyance, to furnish original and duplicate title copies, to pay attorney’s fees of PHP 20,000 and litigation expenses of PHP 10,000, and to pay costs of suit, and it dismissed counterclaims for lack of merit. The RTC found, on the evidence adduced, that an implied trust existed, that respondent paid the purchase price by issuing checks (Exhibits P, Q, R & S), that he exercised actual possession and expended on renovations, and that petitioner admitted receipt of the purchase money.
Court of Appeals Proceedings
Petitioner appealed to the Court of Appeals, which denied the appeal in a Decision dated February 9, 2017 and affirmed the RTC’s findings and decretal relief. Petitioner’s motion for reconsideration was denied in a Resolution dated August 30, 2017. The CA relied on documentary and testimonial evidence, including the checks, renovation receipts and payrolls, tax payments, and homeowners’ dues, to uphold the conclusion that respondent was the beneficial owner.
Issues Presented
The primary issue presented for the Supreme Court’s review was whether respondent had sufficiently proved that an implied trust existed between him and petitioner, thereby rendering respondent the beneficial owner entitled to reconveyance.
Parties' Contentions
Petitioner contended that no implied trust was proven because respondent intended the property to be registered in her name when he allowed her to enter the contract as buyer, that payments of purchase price, association dues, realty taxes and improvements were not conclusive proof of ownership, and that respondent’s alleged silence and failure to assert rights during registration constituted acquiescence. Respondent maintained that he paid the full purchase price through petitioner, that he took immediate and continuous possession, that he invested in major renovations, that he paid taxes and association dues, and that he repeatedly demanded reconveyance but that petitioner refused, thus establishing an implied trust in his favor.
Supreme Court Ruling
The Supreme Court denied the petition for review on certiorari and affirmed the February 9, 2017 Decision and August 30, 2017 Resolution of the Court of Appeals for lack of merit, with costs on petitioner. The Court noted and acted on memoranda filed by the parties in compliance with prior orders. The Decision was concurred in by the Members noted in the roll.
Legal Basis and Reasoning
The Court first observed the limited scope of a petition under Rule 45, Rules of Court, Section 1, which confines review to questions of law and precludes reexamination of factual findings except under recognized exceptions; none of those exceptions obtained in this case. The Court reiterated that an implied trust arises by operation of law where the legal estate is granted to one party but the purchase price is paid by another with the expectation that the latter will enjoy the beneficial interest, citing Article 1448, Civil Code, and that, where property is acquired by fraud or mistake, Article 1456, Civil Code, likewise imposes a trust by force of law. The Court emphasized that the burden of proving a trust rests on the party asserting it and that, while oral evidence may suffice, it must be trustworthy and received with caution. Applying these principles, the Court found that respondent proved by a preponderance of evidence that he supplied
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Case Syllabus (G.R. No. 233775)
Parties and Procedural Posture
- Doris Marie S. Lopez was the petitioner before the Supreme Court after appealing the denial of her CA appeal from the RTC decision adjudicating Civil Case No. 70886-PSG.
- Aniceto G. Saludo, Jr. was the respondent and plaintiff below who sued for reconveyance and damages and sought a temporary restraining order and preliminary injunction.
- The Regional Trial Court, Pasig City, Branch 67 rendered the initial decision on November 5, 2010, which the Court of Appeals affirmed by Decision dated February 9, 2017 and Resolution dated August 30, 2017.
- The petitioner filed a Petition for Review on Certiorari under Rule 45, Rules of Court before the Supreme Court challenging errors of law in the CA rulings.
Key Factual Allegations
- Aniceto G. Saludo, Jr. alleged that sometime in April or May 1997 he entrusted P15,000,000.00 to petitioner to purchase two parcels in Barrio Pineda, Pasig City, with petitioner to hold title in trust and reconvey the properties to him.
- Doris Marie S. Lopez was alleged to have acted as the nominal buyer because the vendor preferred to deal only with her, and respondent alleged repeated assurances that the titles were clean and that TCTs would be issued in his name.
- Respondent presented four checks issued in petitioner’s name and claimed continuous actual possession, payment of real property taxes for thirteen years, payment of homeowner’s association dues, and P9,000,000.00 in major renovations.
- Petitioner asserted that she bought the properties under a pacto de retro and later by a Deed of Absolute Sale dated May 25, 1999, resulting in TCT Nos. PT-111136 and PT-111137 issued in her name.
Trial Court Ruling
- The RTC declared respondent the absolute and rightful owner of the parcels covered by TCT Nos. PT-111136 and PT-111137 in its November 5, 2010 Decision.
- The RTC ordered petitioner to execute a Deed of Reconveyance, deliver original and duplicate title copies, pay attorney’s fees of Php20,000.00 and litigation expenses of 10,000.00, and pay costs of suit.
- The RTC found an implied trust based on respondent’s payment of the purchase price and his continuous possession and expenditures on the properties.
- The RTC dismissed counterclaims for lack of merit.
Court of Appeals Ruling
- The Court of Appeals affirmed the RTC by Decision dated February 9, 2017 and denied petitioner’s motion for reconsideration in its August 30, 2017 Resolution.
- The CA found credible testimonial and documentary evidence of respondent’s payment, renovation receipts, payroll records, tax payments, and homeowner’s dues supporting beneficial ownership.
- The CA concluded that the factual findings established an implied resulting trust in favor of respondent and that petitione