G.R. No. 249754. October 19, 2022.
THE HEIRS OF TEODORO RIBAC, REPRESENTED BY HIS HEIRS AND ISSUES: AUGUSTINA, MARIANO, VICTOR, REYNANTE, DAYLA, AND ROSALIE, ALL SURNAMED RIBAC, PETITIONERS, VS. NARCISA RIBAC-PUTOLAN AND ANTONINA RIBAC-BLANCO, RESPONDENTS.

FACTS

The case involves a parcel of agricultural land originally registered under Original Certificate of Title (OCT) No. P-10565 in the name of Teodoro Ribac. Upon Teodoro’s death in 1977, his heirs (petitioners) caused the cancellation of the OCT and secured a new title in their names. Respondents Narcisa and Antonina, sisters of Teodoro, filed a Complaint for Partition, alleging that the property was part of the estate of their parents, Spouses Bartolome and Lucresia Ribac. They claimed Teodoro merely held the title in trust pursuant to an oral family partition in 1960, wherein portions were allocated to each sibling. Respondents asserted they introduced improvements on their allotted portions.
Petitioners defended their ownership, citing the Torrens title in their father’s name and their own possession and cultivation. During trial, petitioners’ former counsel failed to submit their formal offer of evidence, leading the Regional Trial Court (RTC) to declare a waiver of their right to do so. The RTC ruled in favor of respondents, ordering cancellation of petitioners’ title and reconveyance. The Court of Appeals affirmed. Petitioners elevated the case to the Supreme Court via a petition for review on certiorari, which was initially denied. They subsequently filed the subject Motion for Reconsideration.

ISSUE

The core issue is whether the Court of Appeals erred in affirming the RTC’s decision which found the existence of an implied trust over the property in favor of the respondents, and in upholding the denial of petitioners’ right to formally offer their evidence.

RULING

The Supreme Court denied the Motion for Reconsideration and affirmed the lower courts’ rulings. The legal logic proceeds from two key points: evidence on record and the nature of implied trust. First, the Court found no reversible error in the factual findings. The RTC and CA gave credence to the testimonial and documentary evidence presented by respondents, which substantiated the claim of an oral partition and Teodoro’s role as a trustee. Petitioners’ failure to formally offer their exhibits due to their former counsel’s negligence was binding upon them. A client is generally bound by the mistakes of their counsel. The Court found no compelling reason to grant a new trial, as petitioners were not denied due process; they participated in the trial and cross-examined witnesses.
Second, on the substantive law, the Court upheld the finding of an implied trust under Article 1451 of the Civil Code, which arises when property is purchased through funds of another but titled in the buyer’s name. The evidence showed the land was acquired through a homestead patent application filed by the father, Bartolome, suggesting the family funds were used, but the title was placed in Teodoro’s name for the benefit of all heirs. An action for reconveyance based on such an implied trust prescribes in ten years from the issuance of the title. However, prescription does not run against a claimant in actual possession of the property, as respondents were found to be. Therefore, their action was not time-barred. The Torrens title in Teodoro’s name did not foreclose the enforcement of a trust. The Court concluded that the respondents successfully proved by preponderance of evidence that the property was co-owned and held in trust, warranting reconveyance of their rightful shares.