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Ramos v. CA
G.R. No. 108121 May 10, 1994

Facts:

PHHC awarded rights to buy a parcel of land to Central Bank employee,

Herminio Ramos. Herminio sold the same to his co-worker, Lydia Celestino.
Even though the purchase price was paid by Celestino, the said land was titled
under Ramos’ name. After his death, Herminia and his heirs was issued a new
transfer certificate of title claiming that the original owner’s duplicate was lost.
Lydia prayed that new title be declared null and void on the ground that it was
secured thru fraud as owner’s duplicate was in her possession and custody.
Spouses Lydia and Hilario Celestino filed a complaint, where the court ruled in
their favor for ownership over said land based on premise that an implied trust
had been created when PHHC sold the land to Herminio but with beneficial
title to Lydia who paid the purchase price. Herminia and heirs appealed the
decision contending that no implied trust was established.

Issue: Whether or not there was an implied trust established in the instant
case.

Ruling:
No.
A resulting trust is an “intent-enforcing” trust, based on a finding by the
court in view of the relationship of the parties their acts express an intent to
have a trust. If purpose thereof was to evade some rule of common law, courts
will not assist payor in achieving his improper purpose by enforcing said trust
in accordance with the “clean hands” doctrine. An exception to the law on
trusts, a trust is invalid if enforcement thereof would be against public policy.
In the instance case, Lydia was not among the awardees of PHHC and instead
of acquiring it directly from them, she acquired said land through one of the
awardees, Herminio Ramos. Since the transaction was clearly painted with bad
faith, there is no trust as it is invalid.

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