Petitioner
Spouses Armando
Respondent
Dona Marie Glenn Imson
Citation
G.R. No. 197728
Court
Supreme Court
Division
Third Division
Ponente
Peralta, J.
Decided
September 16, 2015

Summary

Spouses Trinidad filed an ejectment case against Imson claiming ownership of a condominium unit based on notarized deeds in Armando's name. Imson defended claiming she was the true owner who paid for the property but had it registered in Armando's name under a trust arrangement. The MeTC and CA found in favor of Imson, while the RTC ruled for the Trinidads. The Supreme Court affirmed the CA, finding that Imson's evidence of actual payment of the purchase price, taxes, and expenses sufficiently proved an implied trust under Article 1448 of the Civil Code. The Court held that despite the notarized documents, parol evidence was admissible to prove the true intent of the parties, and that valuable consideration, not legal title, determines equitable ownership. The case establishes that implied trusts can be proven through circumstantial evidence of payment and conduct, overcoming the presumption of notarized documents when the true agreement differs from what appears in writing.

Statutes applied

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By the Intellegal Editorial Board · September 16, 2015

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