RAMOS VS.

RAMOS Case Digest

RAMOS VS. RAMOS
61 SCRA 284

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. 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 judges 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 martins 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 fathers 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.