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FACTS: Spouses Martin Ramos and Candida Tanate died on October 4,

1906 and October 26, 1880, respectively. They were survived by their
3 children. Moreover, Martin was survived by his 7 natural children. In
December 1906, a special proceeding for the settlement of the
intestate estate of said spouses was conducted. Rafael Ramos, a
brother of Martin, administered the estate for more than 6 years.
Eventually, a partition project was submitted which was signed by the 3
legitimate children and 2 of the 7 natural children. A certain Timoteo
Zayco signed in representation of the other 5 natural children who
were minors. The partition was sworn to before a justice of peace.

The conjugal hereditary estate was appraised at P74,984.93, consisting


of 18 parcels of land, some head of cattle and the advances to the
legitimate children. ½ thereof represented the estate of Martin. 1/3
thereof was the free portion or P12,497.98. The shares of the 7
natural children were to be taken from that 1/3 free portion. Indeed,
the partition was made in accordance with the Old Civil code.
Thereafter, Judge Richard Campbell approved the partition project.
The court declared that the proceeding will be considered closed and
the record should be archived as soon as proof was submitted that
each he3ir had received the portion adjudicated to him.

On February 3, 1914, Judge Nepumoceno asked the administrator to


submit a report showing that the shares of the heirs had been
delivered to them as required by the previous decision. Nevertheless,
the manifestation was not in strict conformity with the terms of the
judge’s order and with the partition project itself. 8 lots of the
Himamaylan Cadastre were registered in equal shares in the names of
Gregoria (widow of Jose Ramos) and her daughter, when in fact the
administrator was supposed to pay the cash adjudications to each of
them as enshrined in the partition project. Plaintiffs were then
constrained to bring the suit before the court seeking for the
reconveyance in their favor their corresponding participations in said
parcels of land in accordance with Article 840 of the old Civil Code.
Note that 1/6 of the subject lots represents the 1/3 free portion of
martin’s shares which will eventually redound to the shares of his 7
legally acknowledged natural children. The petitioners’ action was
predicated on the theory that their shares were merely held in trust
by defendants. Nonetheless, no Deed of Trust was alleged and proven.
Ultimately, the lower court dismissed the complaint on the grounds of
res judicata, prescription and laches.

ISSUE: Whether or not the plaintiffs’ action was barred by


prescription, laches and res judicata to the effect that they were
denied of their right to share in their father’s estate.

RULING: YES, there was inexcusable delay thereby making the


plaintiffs’ action unquestionably barred by prescription and laches and
also by res judicata. Inextricably interwoven with the questions of
prescription and res judicata is the question on the existence of a
trust. It is noteworthy that the main thrust of plaintiffs’ action is the
alleged holding of their shares in trust by defendants. Emanating from
such, the Supreme Court elucidated on the nature of trusts and the
availability of prescription and laches to bar the action for
reconveyance of property allegedly held in trust. It is said that trust is
the right, enforceable solely in equity to the beneficial enjoyment of
property, the legal title to which is vested in another. It may either be
express or implied. The latter ids further subdivided into resulting and
constructive trusts. Applying it now to the case at bar, the plaintiffs
did not prove any express trust. Neither did they specify the kind of
implied trust contemplated in their action. Therefore, its enforcement
maybe barred by laches and prescription whether they contemplate a
resulting or a constructive trust.

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