Rodolfo Tigno v. Court of Appeals

Summary

This Supreme Court case established that an implied trust under Article 1448 of the Civil Code was created when Eduardo Tigno paid the full purchase price of P30,000 for three fishpond parcels but had them titled in his brother Rodolfo's name to facilitate mortgage applications with PNB. The Court applied the purchase money resulting trust doctrine, finding that despite the deeds naming Rodolfo as vendee, Eduardo remained the beneficial owner since he provided all consideration. When Rodolfo unauthorizedly sold a portion to the Casipits, the Court nullified the sale, ruling that a trustee cannot transfer ownership he doesn't possess. The decision reinforced that oral evidence can prove implied trusts and that good faith of subsequent purchasers is immaterial when the vendor lacks ownership rights. The case demonstrates judicial protection of trust relationships and equitable ownership principles in family property transactions.