G.R. No. 147863 ; August 13, 2004
PROSPERO RINGOR, ET AL., petitioners, vs. CONCORDIA RINGOR, ET AL., respondents.

FACTS

The case involves the estate of Jacobo Ringor. Jacobo had a son, Juan, who predeceased him. Juan had seven children: Jose (predecessor of petitioners) and six others (predecessors of respondents). Jacobo applied for land registration of several parcels. In one application (Expediente 241), the decree adjudicated parcels to Jacobo and his son Juan as pro-indiviso co-owners, despite Jacobo being the sole applicant. Jacobo later executed Compraventas (deeds of sale) in 1928, marked with his thumbprint, purportedly selling all his interests in these lands to his grandson, Jose. Original Certificates of Title were eventually cancelled and Transfer Certificates of Title were issued solely in Jose’s name. However, Jacobo remained in possession, administered the lands, and distributed produce shares to all of Juan’s children until his death in 1935. Jose then assumed administration, continuing the shares. After Jose’s death in 1971, his heirs (petitioners) refused demands for partition from the other heirs (respondents), leading to a complaint for partition and reconveyance.

ISSUE

Whether the Compraventas executed by Jacobo Ringor in favor of his grandson, Jose Ringor, were absolute sales or constituted an express trust for the benefit of all of Juan’s children.

RULING

The Supreme Court ruled that the transactions created an express trust, not an absolute sale. The legal logic hinges on the inconsistency between the purported sales and the parties’ contemporaneous and subsequent conduct. Despite the deeds and issuance of titles in Jose’s name, Jacobo retained possession, control, and administration of the properties, treating them as undivided family property. Crucially, he and later Jose consistently gave shares of the produce to all of Juan’s children, conduct utterly incompatible with Jose being the absolute owner. The Court emphasized that the intention to create a trust prevails over the form of the instrument. The circumstances clearly demonstrated Jacobo’s intent to place the legal title in Jose to facilitate management and prevent partition during his lifetime, but to hold the property for the equal benefit of all his grandchildren. The parol evidence rule does not bar proof of such trust, as trusts can be proven by oral evidence. Therefore, Jose held the titles as a trustee, and his heirs (petitioners) are obligated to reconvey the rightful shares to the respondents. The Court affirmed the lower courts’ decisions ordering partition.