Jose Juan Tong v. Go Tiat Kun · G.R. 196023

Petitioner: Jose Juan Tong
Respondent: Go Tiat Kun
Citation: G.R. No. 196023
Court: Supreme Court
Division: First Division
Ponente: Reyes, J.
Decided: April 21, 2014

Summary

This Supreme Court case involves a family property dispute over Lot 998-A between the children of Juan Tong. The petitioners, nine of Juan Tong's children, claimed their deceased brother Luis Sr. held the property only as trustee under an implied resulting trust, while respondents (Luis Sr.'s heirs) claimed ownership by succession. The RTC found an implied resulting trust existed since Juan Tong provided the purchase money but registered the property in Luis Sr.'s name due to citizenship restrictions. The CA reversed, requiring written proof and finding prescription. The Supreme Court reinstated the RTC decision, ruling that parol evidence sufficiently proved the implied resulting trust under Civil Code Article 1448, and that the action was not time-barred. The decision establishes important precedent on implied resulting trusts in family property arrangements and the use of testimonial evidence to prove such trusts.

Statutes applied

Civil Code, Art. 1448

Related cases

Other Philippine cases on the same provisions and issues.

Rodolfo Morales v. Court of Appeals (Former Seventeenth Division) G.R. No. 117228
Spouses Ruth Dizon Devisfruto v. Maxima L. Greenfell G.R. No. 227725
Salvador Comilang v. Francisco Burcena G.R. No. 146853
Felomina Abellana v. Spouses Romeo Ponce G.R. No. 160488
Rodolfo Tigno v. Court of Appeals G.R. No. 110115
Victor R. Trinidad v. Bank of Commerce G.R. No. 214224
Melinda M. Malabanan v. Francisco Malabanan, Jr. G.R. No. 187225
Antonio Feliciano v. Antonio E. Feliciano, Jr. G.R. No. 194922

By the Intellegal Editorial Board · April 21, 2014

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