Spouses Ruth Dizon Devisfruto v. Maxima L. Greenfell

Summary

This case involves an implied trust dispute where Maxima Greenfell, a former Filipino citizen who became Australian, financed the purchase of properties in Zambales but had them registered in her niece Ruth Devisfruto's name. When Greenfell reacquired Philippine citizenship and demanded reconveyance, the Devisfruto Spouses refused, claiming the properties were gratuitously given. All courts from trial to Supreme Court consistently found that an implied trust under Article 1448 of the Civil Code was created, as the legal estate was granted to Ruth while the purchase price was paid by Greenfell for the purpose of having beneficial interest in the property. The Supreme Court affirmed the finding, rejecting arguments about express trust (raised for first time on appeal) and gratuitous donation (lacking required formal compliance under Article 748). The case establishes important precedent on implied trusts in property transactions and procedural rules on raising new issues on appeal.