- Petitioner
- Sps. Felipe
- Respondent
- Marciana P. Bajit
- Citation
- G.R. No. 181844
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Abad, J.
- Decided
- September 29, 2010
Summary
The Supreme Court upheld the existence of an implied trust under Article 1450 of the Civil Code in a property dispute between siblings. Felipe and Josefa Paringit purchased a family lot from Terocel Realty for P60,000.00 after Julian Paringit assigned his leasehold rights to them due to lack of funds. Julian's 1985 affidavit, signed by the siblings, clarified that the purchase was for all children's benefit with Felipe and Josefa as trustees. The Court found the implied trust evidenced by: the family's original ownership rights, Julian's explicit affidavit, the spouses' conduct of allowing siblings to occupy the property for over 10 years, and only asserting ownership claims after Julian's death. The decision establishes important precedent on implied trusts in family property arrangements, holding that the beneficiaries' cause of action only accrues when the trustee repudiates the trust, not when it was created. The siblings were ordered to reimburse Felipe and Josefa their proportionate shares of the P60,000.00 acquisition cost with legal interest from 1984.