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    Roa, Jr. vs. Court of Appeals

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    Pio Guieb Aguilar
    1) Petitioner Roa and his siblings owned land that was subject to an opposition from Pablo Valdehuesa, who claimed a portion. To ensure title issuance, the siblings agreed to replace the disputed portion with equivalent land or pay 400 pesos, upon which Pablo withdrew opposition. 2) Pablo died and his heirs were neither given replacement land nor paid. The originally disputed property was also already partitioned to Petitioner Roa. 3) The court found this created a constructive trust, which equity implies to prevent unjust enrichment from wrongful property acquisitions or retentions against fairness, justice or good conscience.

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    Roa, Jr. vs. Court of Appeals

    Uploaded by

    Pio Guieb Aguilar
    959 views1 page
    1) Petitioner Roa and his siblings owned land that was subject to an opposition from Pablo Valdehuesa, who claimed a portion. To ensure title issuance, the siblings agreed to replace the disputed portion with equivalent land or pay 400 pesos, upon which Pablo withdrew opposition. 2) Pablo died and his heirs were neither given replacement land nor paid. The originally disputed property was also already partitioned to Petitioner Roa. 3) The court found this created a constructive trust, which equity implies to prevent unjust enrichment from wrongful property acquisitions or retentions against fairness, justice or good conscience.

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    1) Petitioner Roa and his siblings owned land that was subject to an opposition from Pablo Valdehuesa, who claimed a portion. To ensure title issuance, the siblings agreed to replace the disputed portion with equivalent land or pay 400 pesos, upon which Pablo withdrew opposition. 2) Pablo died and his heirs were neither given replacement land nor paid. The originally disputed property was also already partitioned to Petitioner Roa. 3) The court found this created a constructive trust, which equity implies to prevent unjust enrichment from wrongful property acquisitions or retentions against fairness, justice or good conscience.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    959 views1 page

    Roa, Jr. vs. Court of Appeals

    Uploaded by

    Pio Guieb Aguilar
    1) Petitioner Roa and his siblings owned land that was subject to an opposition from Pablo Valdehuesa, who claimed a portion. To ensure title issuance, the siblings agreed to replace the disputed portion with equivalent land or pay 400 pesos, upon which Pablo withdrew opposition. 2) Pablo died and his heirs were neither given replacement land nor paid. The originally disputed property was also already partitioned to Petitioner Roa. 3) The court found this created a constructive trust, which equity implies to prevent unjust enrichment from wrongful property acquisitions or retentions against fairness, justice or good conscience.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 1

    Roa, Jr. vs.

    Court of Appeals
    Petitioner: ALFREDO ROA, JR., LETICIA ROA DE BORJA,
    RUBEN ROA, CORNELIO ROA and ELSIE ROA-CACNIO (as
    heirs of the late Alfredo Roa, Sr.)
    Respondent: HON. COURT OF APPEALS and the spouses
    JOAQUIN CASIO and CUSTODIA VALDEHUESA,
    Doctrine: "A constructive trust is substantially an
    appropriate remedy against unjust enrichment. It is raised
    by equity in respect of property, which has been acquired by
    fraud, or where, although acquired originally without fraud,
    it is against equity that it should be retained by the person
    holding it."
    FACTS: Petitioner Roa and his brothers and sisters Trinidad
    Reyes Roa, Esperanza Roa de Ongpin, Concepcion Roa and
    Zosimo Roa, husband of the latter, were the owners proindiviso of a parcel of land located in Tagoloan, Misamis
    Oriental. They filed for the issuance of title but opposition
    was made by one Pablo Valdehuesa for a portion of the land.
    Pablo claimed that the portion was his. In order to ensure
    the issuance of the tittle the siblings entered into a
    compromise agreement with Pablo wherein they would
    replace the lot with another parcel of land of equivalent size
    or if the replacement is not to his liking they would pay him
    400 pesos. As a result of the agreement Pablo withdrew his
    opposition. Pablo died so ownership passed to his heirs, but
    no lot was given as replacement nor were they paid. Also
    the property described in the original agreement was
    partitioned already to the petioner Roa in this case.
    ISSUE: WON the agreement created a trust
    HELD: YES. The court cited American law and Jurisprudence:
    There was a constructive trust, otherwise known as a trust
    ex maleficio, a trust ex delicto, a trust de son tort, an
    involuntary trust, or an implied trust, is a trust by operation
    of law which arises contrary to intention and in invitum,

    against one who, by fraud, actual or constructive, by duress


    or abuse of confidence, by commission of wrong, or by any
    form of unconscionable conduct, artifice, concealment, or
    questionable means, or who in any way against equity and
    good conscience, either has obtained or holds the legal right
    to property which he ought not, in equity and good
    conscience, hold and enjoy. It is raised by equity to satisfy
    the demands of justice. However, a constructive trust does
    not arise on every moral wrong in acquiring or holding
    property or on every abuse of confidence in business or
    other affairs; ordinarily such a trust arises and will be
    declared only on wrongful acquisitions or retentions of
    property of which equity, in accordance with its fundamental
    principles and the traditional exercise of its jurisdiction or in
    accordance with statutory provision, takes cognizance. It
    has been broadly ruled that a breach of confidence,
    although in business or social relations, rendering an
    acquisition or retention of property by one person
    unconscionable against another, raises a constructive trust.
    The court said that what was created was not an express
    trust because in that type of trust the intent nto create one
    needs to be clear even in the absence of particular words.
    Furthermore it could not be an implied trust because the law
    states that Art. 1456. If property is acquired through mistake
    or fraud, the person obtaining it is, by force of law,
    considered a trustee of an implied trust for the benefit of the
    person from whom the property comes. And in this case
    there was no use of force or fraud in play. So basically the
    court concluded that although this type of scenario may not
    fall under the types of implied trusts enumerated in the Civil
    Code, the enumeration given does not preclude the
    existence of other types of trusts that are in line with the
    general law on trusts. In this case the court resolved the
    case on the general principles of law on constructive trust
    which basically rest on equitable considerations in order to
    satisfy the demands of justice, morality, conscience and fair
    dealing and thus protect the innocent against fraud.

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