Miguel J. Ossorio Pension Foundation v. Court of Appeals

Summary

The Supreme Court reversed lower courts' denial of a tax refund claim by Miguel J. Ossorio Pension Foundation, a trustee of VMC employees' trust fund. The foundation claimed co-ownership of real property and sought refund of P3,037,500 withholding tax paid on the property's sale. Lower courts rejected the claim, finding insufficient proof of co-ownership since the title was solely in VMC's name. The Supreme Court applied Civil Code Article 1452, ruling that a resulting trust was created by operation of law when co-owners agreed to register property in one party's name. Combined with evidence from notarized agreements and bank portfolio reports, the Court established the foundation's 49.59% beneficial ownership. Since employees' trust fund income is tax-exempt under the Tax Code, the Court granted the refund, affirming the foundation's right to claim tax benefits as trustee of the exempt pension fund.