Trinidad v. Imson
REITERATIONFacts
The Antecedents: Petitioners filed a complaint for ejectment against respondent for non-payment of rentals for a condominium unit. Petitioners claimed ownership based on a Deed of Assignment and Transfer of Rights dated June 13, 2002, and a Deed of Absolute Sale dated July 13, 2007, both in the name of petitioner Armando Trinidad. Respondent, who was leasing the unit from the original owners, alleged that she had an agreement with Armando Trinidad for him to purchase the unit in his name, but that she was the actual beneficial owner. She claimed to have paid the purchase price, real property taxes, association dues, and utility bills. Procedural History: The Metropolitan Trial Court (MeTC) dismissed the ejectment complaint, finding respondent to be the true owner. The Regional Trial Court (RTC) reversed the MeTC, ruling in favor of petitioners based on the notarized deeds. The Court of Appeals (CA) set aside the RTC decision, finding respondent's evidence more credible and entitling her to possession. The CA denied petitioners' motion for reconsideration. The Petition: Petitioners seek review of the CA decision, raising issues on whether respondent's evidence suffices to provisionally declare her as owner, whether she paid the consideration for the Deed of Assignment, and whether an implied trust was created.
Issue(s)
Whether the pieces of evidence presented by the respondent suffice to provisionally declare her as the owner of the subject condominium unit, and whether the Parol Evidence Rule applies. Whether the respondent is estopped from claiming ownership as a tenant. Whether an implied trust was created in favor of the respondent.
Ruling
The petition is denied. The Decision and Resolution of the Court of Appeals are affirmed. Respondent is entitled to the possession of the subject condominium unit.
Ratio Decidendi
On the issue of ownership, respondent's evidence, and the Parol Evidence Rule: The Court held that while the Deed of Assignment and Transfer of Rights and the Deed of Absolute Sale are notarized documents enjoying a presumption of regularity, this presumption is only prima facie and can be overcome by clear and convincing evidence. The respondent presented checks from her personal account paid to the former owners, acknowledgment receipts of payments, real property tax receipts, certifications of payment of association dues and utilities, and an affidavit from the former owners. These pieces of evidence, coupled with the surrounding circumstances, were deemed sufficient by the MeTC and CA to overcome the prima facie presumption of the notarized documents. The Court found no error in this conclusion, noting the petitioners' failure to provide credible explanations for the respondent's payments and the former owners' affidavit. The Court clarified that the Parol Evidence Rule is not ironclad. Section 9, Rule 130 of the Rules of Court provides exceptions, including when a party puts in issue in their pleading the failure of the written agreement to express the true intent and agreement of the parties. In this case, the respondent squarely raised in her Answer that the Deed of Assignment and Transfer of Rights did not express the true intent of the parties, thus falling under the exception. On the issue of estoppel against tenants: The Court distinguished the application of Article 1436 of the Civil Code and Section 2(b), Rule 131 of the Rules of Court. The tenant is estopped from denying the landlord's title only at the commencement of the landlord-tenant relation. If the tenant claims title acquired subsequent to the commencement of the relation, the presumption does not apply. Here, the respondent claimed title acquired subsequent to her lease agreement with the original owners, thus she was not estopped from asserting her ownership. On the existence of an implied trust: The Court affirmed the findings of the lower courts that an implied trust was created. Citing Article 1448 of the Civil Code, an implied trust exists when property is sold and legal title is granted to one party, but the price is paid by another for the beneficial interest of the latter. The elements are actual payment of consideration by the beneficiary and the intention, presumed from the circumstances, to hold the legal title for the beneficiary. The respondent's evidence, including her payments and the former owners' affidavit, sufficiently proved the existence of such an implied trust, where petitioner Armando Trinidad held the legal title in trust for the respondent.
Main Doctrine
The presumption of truth of facts stated in notarized documents is merely prima facie and can be overcome by clear and convincing evidence. Furthermore, the parol evidence rule allows for the presentation of evidence to explain or modify written agreements when the true intent of the parties is put in issue.