GR 858; (January, 1903) (Digest)
G.R. No. 858 : January 23, 1903
FRANCISCO MARTINEZ, plaintiff-appellee, vs. PEDRO MARTINEZ, defendant-appellant.
FACTS:
Francisco Martinez filed an action against his son, Pedro Martinez, to recover ownership of two vessels, the steamer Balayan and the schooner Ogoño. The titles to both vessels were registered in the name of the defendant, Pedro Martinez. Francisco Martinez alleged that the vessels were purchased with funds he provided. The trial court ruled in favor of the plaintiff, finding him to be the true owner despite the registration in the defendant’s name. The defendant appealed, arguing that the registered title established his ownership.
ISSUE:
Whether the payment of the purchase price by the plaintiff, Francisco Martinez, for property titled and registered in the name of the defendant, Pedro Martinez, by itself, transfers legal or equitable ownership of the property to the plaintiff.
RULING:
No. The Supreme Court reversed the trial court’s decision and ordered a new trial.
The Court held that the registered legal title in the defendant’s name must be respected. The mere fact that the plaintiff furnished the money used to purchase the property does not, under the applicable provisions of the Civil Code, operate to transfer the ownership of the property to him. Ownership is acquired by the modes specified in law (such as donation, succession, or contract), none of which were present here. The Court found no evidence of an agency relationship or any other contract between the father and son that would justify holding the property for the plaintiff’s benefit. The applicable Spanish laws (Partidas) did not support the plaintiff’s claim, and the Anglo-American doctrine of resulting trust was not in force. The plaintiff’s exercise of acts of dominion over the vessels and a letter from the defendant referring to the plaintiff in connection with a potential sale were insufficient to overcome the registered title. Any right the plaintiff may have is limited to a possible personal action for recovery of the money, not an assertion of ownership over the vessels themselves.