- Petitioner
- Estate of Margarita D. Cabacungan
- Respondent
- Marilou Laigo
- Citation
- G.R. No. 175073
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Peralta, J.
- Decided
- August 15, 2011
Summary
This case involves a family property dispute where Margarita Cabacungan transferred three parcels of unregistered land to her son Roberto in 1968 to support his US visa application, with the understanding he would return them. Roberto later sold the properties to respondents in 1990-1992 without Margarita's knowledge. The Supreme Court reversed lower courts, finding an implied resulting trust existed based on testimonial evidence of the accommodation arrangement. The Court ruled that protection for good faith buyers does not apply to unregistered lands, and that respondents acquired no better title than Roberto possessed. The Court applied constructive trust principles under Article 1456, rejected prescription and laches defenses, and ordered reconveyance of the properties to Margarita's estate, emphasizing that family relationships excuse delays in asserting property rights.