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.