Case Summary (G.R. No. 227725)
Background of the Case
On October 18, 2011, Greenfell, a natural-born Filipino who later became an Australian citizen, filed a Complaint for Reconveyance and Damages against the Devisfruto Spouses in the Municipal Circuit Trial Court. Greenfell alleged she financed the purchase of a house and two lots from the Magisa Spouses, but the properties were registered in her niece Ruth's name. Greenfell contended that a trust was formed, mandating that the properties be transferred back to her upon her reacquisition of Philippine citizenship in 2009.
Municipal Circuit Trial Court Decision
The Municipal Circuit Trial Court ruled in favor of Greenfell. It recognized the existence of a purchase money resulting trust under Article 1448 of the Civil Code, asserting that Ruth held legal title merely as a depository for Greenfell. Thus, the court ordered the Devisfruto Spouses to reconvey the properties to Greenfell and awarded her attorney's fees and costs.
Regional Trial Court and Court of Appeals Review
The Devisfruto Spouses sought to appeal this decision. The Regional Trial Court upheld the Municipal Circuit Trial Court's ruling. They then filed a Petition for Review with the Court of Appeals, which concluded that an implied trust had indeed been created and dismissed their petition. The appellate court emphasized that the intention to create a trust was supported by testimony from the properties' former owner.
Arguments Raised by Petitioners
In the subsequent motion for reconsideration and the petition for review before the Supreme Court, the Devisfruto Spouses contended that no trust had been established, claiming any purported trust was express and not supported by documentary evidence. They further insisted that the properties were gifts due to the close familial relationship and claimed that Greenfell had only sought legal recourse after their relationship deteriorated.
Respondent’s Position
In response, Greenfell maintained her position on the ownership of the properties, supported by the testimony of the original owner, Dante Magisa, who affirmed the arrangement that Ruth was to convey the properties back to Greenfell upon her return to the Philippines.
Supreme Court Findings and Decision
The Supreme Court analyzed the nature of the trust formed under Article 1448 of the Civil Code, establishing that it is created when one party pays for a property while another holds legal title. The Court found that both lower courts correctly determined that the legal title was held by Ruth while the purchase money was supplied by Greenfell, aimed at providing her beneficial interest in the property.
Petitioners
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Case Background
- Maxima Greenfell filed a Complaint for Reconveyance and Damages against Spouses Ruth Dizon Devisfruto and Allan Devisfruto in the Municipal Circuit Trial Court.
- Greenfell is a natural-born Filipino citizen who later became an Australian citizen and reacquired her Filipino citizenship under Republic Act No. 9225.
- Before reacquiring her citizenship, Greenfell financed the purchase of a house and two lots in Tampo, Botolan, Zambales, registered under her niece, Ruth Dizon Devisfruto.
- The properties were acquired from Spouses Dante and Erna Magisa for P20,000.00 and P25,000.00, respectively.
- The Devisfruto Spouses claimed ownership and possessed the properties, declaring them under Tax Declaration Nos. 021-0464R and 021-0659R, which were later consolidated.
Proceedings in Lower Courts
- In April 2009, Greenfell requested the transfer of the properties to her name, which Ruth refused.
- The Municipal Circuit Trial Court ruled in favor of Greenfell, establishing a purchase money resulting trust under Article 1448 of the Civil Code.
- The court concluded that Ruth was a mere depository of the legal title, obligated to transfer the properties back to Greenfell upon her request.
- The dispositive portion ordered the Devisfruto Spouses to reconvey the properties and pay Greenfell attorney’s fees and costs.
Appeal to the Regional Trial Court
- The Devisfruto Spouses appealed the decision to the Regional Trial Court, wh