Friday, August 9, 2013

Palma vs. Cristobal, 77 Phil. 712

Facts:
·         Pablo D. Palma filed an ejectment against Eduardo Reyes Cristobal of a parcel of land in Tondo, Manila. It was decided in favor of Cristobal. He filed a petition to be declared the owner of the land. Petition was dismissed by the TC and CA.
·         1909 – OCT 1627 issued in the names of Pablo Palma and Luisa Cristobal.
·         1923 – OCT 1627 cancelled and substituted by TCT 20968
·         Substituted by TCT 26794 in the name of PP and LC
·         1922 – Luisa Critobal died and the certificate was substituted with only the name of Pablo Palma.
·         CFI:
o    community property held by Pablo Palma in trust for the real owners. Eduardo Reyes Cristobal is an heir of the real owners.
o    Registered by reason of the confidence of the co-owners  to PP and LC #peaches
o    Co-owners were receiving their shares in the rentals so they did not partition
·         CA:
o    At the death of LC and PP had taken a second wife that trouble arose between PP and ERC.
o    LC on her deathbed asked PP to give her co-owners theirs shares in the parcel of land
Issue and Ruling:
·         1st Issue
o    Petitioner: CA considered the oral testimony to re rebut the legal presumption that he is the owner of the land
o    Court: Fiduciary relationship between PP and ERC. As an agent, he cannot assert a title adverse to that of the principal
·         2nd Issue        
o    Petitioner: After LC died n 1922, instead of partitioning the property, considering that PP promised the partition, ERC appeared as attorney for petitioner and prayed that a new TCT be issued as the sole owner of the property.
o    ERC party to the fraud upon court and that estops him from asserting that he is the co-owner of the land.
o    Court: Fact that ERC is a party to the deception is not a valid reason for changing the legal relationship between the petitioner and its true owners. Fraud cannot affect the substantial rights of the real owners.
o    ERC is not barred because his appearance as attorney for petitioner was not a misrepresentation which would induce petitioner to believe that respondent recognized PP as the sole owner.
o    ERC’s appearance as attorney for petitioner in 1923 was a consequence of the understanding, and petitioner could not legitimately assume that it had the effect of breaking or reversing said understanding.
·         3rd Issue
o    Petitioner: He acquired absolute ownership through prescription. When he caused the trust property and partitioned it between himself and his daughter Ildelfonsa Cristobal Ditangco he openly breached the agreement of 1909 and his promise to his dying wife and that breach was an assumption of ownership.

o    Court: PP cannot acquire it by prescription because he held it in a fiduciary capacity. Position is that of a cestui que trust.

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