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Ringor Vs Ringor

This case involves a dispute over lands owned by Jacobo Ringor. Jacobo had three different land registration cases to register parcels of land. After Jacobo's death, his heirs (respondents) demanded a share of the estate but Jacobo's grandson Jose's heirs (petitioners) refused to partition the lands. The trial court ruled that Jacobo had created an express trust over the lands in favor of his grandchildren, with Jose as the trustee. The issue is whether parol evidence can be used to prove the establishment of an express trust. The court held that parol evidence is allowed to prove an express trust exists, as intention to create a trust can be inferred from circumstances. A trustee cannot repudiate a

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382 views1 page

Ringor Vs Ringor

This case involves a dispute over lands owned by Jacobo Ringor. Jacobo had three different land registration cases to register parcels of land. After Jacobo's death, his heirs (respondents) demanded a share of the estate but Jacobo's grandson Jose's heirs (petitioners) refused to partition the lands. The trial court ruled that Jacobo had created an express trust over the lands in favor of his grandchildren, with Jose as the trustee. The issue is whether parol evidence can be used to prove the establishment of an express trust. The court held that parol evidence is allowed to prove an express trust exists, as intention to create a trust can be inferred from circumstances. A trustee cannot repudiate a

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moyaaaeee
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd

Ringor, et. al vs Ringor et. al G.R. No.

147863 August 13, 2004


Facts:
This case involves a dispute over lands owned by the late Jacobo Ringor in San Fabian,
Pangasinan. Jacobo had three different land registration cases to register these lands,
and in each case, he was eventually joined by his son Juan or his grandson Jose as
applicants.
In the first land registration case, Parcel 1 and Parcel 2 were adjudicated to Jacobo and
Juan in equal shares. In the second case, Parcel 3 was awarded to Jacobo. In the third
case, Parcel 1 was divided between Jacobo and Jose, while Parcels 2 and 3 were
mostly given to Jacobo with a smaller portion to Jose. Despite these registrations,
Jacobo continued to possess and administer the lands, sharing the produce with his
children and grandchildren. Jacobo died in 1935, and Jose, continued the administration
of the lands, maintaining the practice of sharing the produce with his siblings and
cousins.
In 1973, after Jose's death, respondents (the heirs of Jacobo) demanded their share in
the estate left by Jacobo. However, petitioners (the heirs of Jose) refused to partition the
lands. Respondents filed a complaint for partition, reconveyance, and damages in 1973.
The trial court decided in favor of the respondents, ruling that Jacobo had created an
express trust over the lands in favor of his grandchildren, with Jose as the trustee. The
trial court considered oral evidence to establish the existence of the express trust. The
Court of Appeals affirmed the trial court's decision, and petitioners' motion for
reconsideration was denied.
Issue:
May parol evidence be used as proof of the establishment of the express trust?
Held:
Express trusts, sometimes referred to as direct trusts, are intentionally created by the
direct and positive acts of the settlor or the trustor by some writing, deed, or will, or oral
declaration. Contrary to the claim of petitioners, oral testimony is allowed to prove that a
trust exists. It is not error for the court to rely on parol evidence, i.e., the oral testimonies
of the witnesses - which the CA also relied on to arrive at the conclusion that an express
trust exists. What is crucial is the intention to create a trust. While oftentimes the
intention is manifested by the trustor in express or explicit language, such intention may
be manifested by inference from what the trustor has said or done, from the nature of
the transaction, or from the circumstances surrounding the creation of the purported
trust. Further, A trustee who obtains a Torrens title over a property held in trust for him
by another cannot repudiate the trust by relying on the registration.

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