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. ½ 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 judge’s 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 martin’s 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 father’s 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.