Eulogio M. Pedrano v. Heirs of Benedicto Pedrano

Summary

This family property dispute involved Lot No. 6416 in Zamboanga del Sur originally purchased by Romana Pedrano from Dr. Hynson in 1965. Romana's son Eulogio claimed ownership through a 1981 deed of sale requiring payment of ₱30,000 by December 31, 1982. When Eulogio failed to pay, Romana's heirs sought annulment of the sale in 1996. The trial court dismissed for prescription, but the Court of Appeals reversed, finding an implied trust since no payment occurred. The Supreme Court affirmed with modification, ruling that Eulogio held the property as implied trustee for all six heirs of Benedicto and Romana Pedrano, each entitled to a 1/6 share. The case establishes that prescription for reconveyance based on implied trust runs from certificate of title issuance, not deed execution, and that unpaid consideration creates an implied trust relationship.