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RINGOR v. RINGOR

This case has been cited 6 times or more.

	GR No. 196023 2014-04-21	JOSE JUAN TONG v. GO TIAT KUN REYES, J.
As a rule, implied resulting trusts do not prescribe except when the trustee repudiates the trust. Further, the action to reconvey does not prescribe so long as the property stands in the name of the trustee.[19] To allow prescription would be tantamount to allowing a trustee to acquire title against his principal and true owner. It should be noted that the title of Lot 998 was still registered in the name of Luis Sr. even when he predeceased Juan Tong. Considering that the implied trust has been repudiated through such death, Lot 998 cannot be included in his estate except only insofar as his undivided share thereof is concerned. It is well-settled that title to property does not vest ownership but it is a mere proof that such property has been registered. And, the fact that the petitioners are in possession of all the tax receipts and tax declarations of Lot 998 all the more amplify their claim of ownership over Lot 998-A. Although these tax declarations or realty tax payments of property are not conclusive evidence of ownership, nevertheless, they are good indicia of possession in the concept of owner, for no one in his right mind would be paying taxes for a property that is not in his actual or at least constructive possession. Such realty tax payments constitute proof that the holder has a claim of title over the property.[20] Therefore, the action for reconveyance of Lot 998-A, which forms part of Lot 998, is imprescriptible and the petitioners are not estopped from claiming ownership thereof.
	GR No. 140528 2011-12-07	TOSINO v. SPS. ANDRES T. ROSARIO AND LENA DUQUE-ROSARIO AND BANCO FILIPINO SAVINGS AND MORTGAGE BANK LEONARDO-DE CASTRO, J.
The Court already rejected a similar argument in Ringor v. Ringor [69] for the following reasons: A trustee who obtains a Torrens title over a property held in trust for him by another cannot repudiate the trust by relying on the registration. A Torrens Certificate of Title in Jose's name did not vest ownership of the land upon him. The Torrens system does not create or vest title. It only confirms and records title already existing and vested. It does not protect a usurper from the true owner. The Torrens system was not intended to foment betrayal in the performance of a trust. It does not permit one to enrich himself at the expense of another. Where one does not have a rightful claim to the property, the Torrens system of registration can confirm or record nothing. Petitioners cannot rely on the registration of the lands in Jose's name nor in the name of the Heirs of Jose M. Ringor, Inc., for the wrong result they seek. For Jose could not repudiate a trust by relying on a Torrens title he held in trust for his co-heirs. The beneficiaries are entitled to enforce the trust, notwithstanding the irrevocability of the Torrens title. The intended trust must be sustained. [70] (Emphasis supplied.)
	GR No. 171805 2011-05-30	PHILIPPINE NATIONAL BANK v. MERELO B. AZNAR LEONARDO-DE CASTRO, J.
Express trusts, sometimes referred to as direct trusts, are intentionally created by the direct and positive acts of the settlor or the trustor - by some writing, deed, or will or oral declaration. It is created not necessarily by some written words, but by the direct and positive acts of the parties.[22] This is in consonance with Article 1444 of the Civil Code, which states that "[n]o particular words are required for the creation of an express trust, it being sufficient that a trust is clearly intended."
	GR No. 173533 2009-12-14	VICENTE N. LUNA v. NARIO CABALES CARPIO MORALES, J.
The registration of a property in one's name, whether by mistake or fraud, the real owner being another, impresses upon the title so acquired the character of a constructive trust for the real owner.[32] The person in whose name the land is registered holds it as a mere trustee, and the real owner is entitled to file an action for reconveyance of the property.[33] The Torrens system does not protect a usurper from the true owner.[34]
	GR No. 148788 2007-11-23	SOLEDAD CAÑEZO v. CONCEPCION ROJAS NACHURA, J.
Acquisitive prescription may bar the action of the beneficiary against the trustee in an express trust for the recovery of the property held in trust where (a) the trustee has performed unequivocal acts of repudiation amounting to an ouster of the cestui que trust; (b) such positive acts of repudiation have been made known to the cestui que trust, and (c) the evidence thereon is clear and conclusive.[26] As a rule, however, the burden of proving the existence of a trust is on the party asserting its existence, and such proof must be clear and satisfactorily show the existence of the trust and its elements.[27] The presence of the following elements must be proved: (1) a trustor or settlor who executes the instrument creating the trust; (2) a trustee, who is the person expressly designated to carry out the trust; (3) the trust res, consisting of duly identified and definite real properties; and (4) the cestui que trust, or beneficiaries whose identity must be clear.[28] Accordingly, it was incumbent upon petitioner to prove the existence of the trust relationship. And petitioner sadly failed to discharge that burden.
	GR NO. 163081 2007-06-15	ANITA UNGAB-VALEROSO v. AMANCIA UNGAB-GRADO QUISUMBING, J.
Petitioners argue that the co-ownership was already extinguished because the Civil Code provides that an agreement to keep a thing undivided shall not exceed ten years. Indeed, the law limits the term of a co-ownership to ten years, but this term limit may nevertheless be extended.[14] The action to reconvey does not prescribe so long as the property stands in the name of the trustee. To allow prescription would be tantamount to allowing a trustee to acquire title against his principal and true owner.[15]