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HEIRS OF LORENZO YAP v. CA

FACTS:

In this case, petitioners are seeking the enforcement of an alleged trust agreement between Lorenzo Yap and his brothers Ramon and Benjamin Yap, wherein they claim ownership over a piece of land and its improvement. Ramon Yap purchased the said land in 1966 and constructed a two-storey apartment building on it. The cost of construction was shared between Ramon Yap and Chua Mia, the mother of Lorenzo, Benjamin, and Ramon. Upon completion of the improvement, it was declared for real estate tax purposes in the name of Lorenzo Yap. After Lorenzo Yap's death, his heirs (petitioners) started residing permanently in Manila and were allowed by Ramon Yap to use one unit of the apartment building. Subsequently, Ramon Yap sold the land and his share of the apartment to Benjamin Yap. Petitioners then claimed ownership of the property and demanded that the title be transferred to them. Respondents filed an action for quieting of title against the petitioners, and the trial court ruled in favor of the respondents, declaring Benjamin Yap as the true owner of the property. The Court of Appeals affirmed the decision but deleted the award of attorney's fees in favor of the respondents. Petitioners appealed to the Supreme Court.

ISSUES:

  1. Whether there is an enforceable trust agreement between Lorenzo Yap, now deceased, and his brothers Ramon and Benjamin.

  2. Whether Benjamin Yap is the true and lawful owner of the disputed property.

RULING:

  1. The Court of Appeals held that there is no clear and convincing evidence to prove the existence of a trust agreement between Lorenzo Yap and his brothers Ramon and Benjamin. The appellate court upheld the presumption of regularity in the execution of the Deed of Sale between Ramon and Benjamin Yap.

  2. The Court of Appeals affirmed the decision of the trial court, ruling that Benjamin Yap is the true and lawful owner of the disputed property.

PRINCIPLES:

  • The evidence to overcome the presumption of regularity in the execution of a public document should be clear and convincing.

  • The claimant has the burden of proving the existence of a trust agreement.

  • Ownership of property is determined by the respective titles registered in the name of the parties.