Ramos vs CA

G.R. No. 108121

Facts:

Herminio Ramos sold to Lydia Celestino, both Central Bank employees, his rights to buy a parcel of land
under the People’s Homesite & Housing Corporation. The corresponding transfer certificate of title was
then issued in the name of Ramos, and the duplicate copy was then delivered to Lydia’s possession. A
Special Power of Attorney was then executed in favor of Lydia to do any act of disposition over the
property in controversy, and this recognized the existing implied trust between the two parties.
However, in another civil case, the Court awarded the duplicate copy of the TCT to Ramos, declaring the
same to have been lost. Hence, Celestino filed an action. The lower Court recognized that there was an
implied trust and that the action for reconveyance had not yet prescribed. Petitioners argued that the
lower Court erred in its decision. It was then revealed that Celestino concealed their transaction with
Ramos, to avoid her disqualification to acquire a lot from the PHHC.

Issue:

Whether or not Celestino can ask for the reconveyance of the property on the basis of a resulting trust.

Held:

No. A resulting trust is an "intent-enforcing" trust, based on a finding by the court that in view of the
relationship of the parties their acts express an intent to have a trust, even though they did not use
language to that effect. However, if the purpose of the payor of the consideration in having title placed
in the name of another was to evade some rule of the common or statute law, the courts will not assist
the payor in achieving his improper purpose by enforcing a resulting trust for him in accordance with the
"clean hands" doctrine. Otherwise stated, as an exception to the law on trusts, "[a] trust or a provision
in the terms of a trust is invalid if the enforcement of the trust or provision would be against public
policy, even though its performance does not involve the commission of a criminal or tortious act by the
trustee."