Weeks 7 & 8 Coverage Table
The table below mirrors the syllabus list for September 23 and 30, 2026. Entries marked supra re-assign a case already digested; the link points to that original digest.
| # | Assigned Case | Topic/Subtopic | Digest |
|---|---|---|---|
| 1 | Goyanko, Jr. v. United Coconut Planters Bank, G.R. No. 179096, February 6, 2013 | 1. Express Trusts (Arts. 1443 - 1446) — Elements | |
| 2 | Cañezo v. Rojas, G.R. No. 148788, November 23, 2007 | 1. Express Trusts (Arts. 1443 - 1446) — How proven (Art. 1443) | |
| 3 | Cañezo v. Rojas, supra | 1. Express Trusts (Arts. 1443 - 1446) — Creation of an express trust (Art. 1444) | |
| 4 | Torbela v. Spouses Rosario, G.R. Nos. 140528 & 140553, December 7, 2011 | 2. Implied Trusts (Art. 1447 - 1457) — a. Resulting Trusts (Art. 1448-1455) — Legal title to land inherited by heir but placed in the name of another (Art. 1451) | |
| 5 | Sumaoang v. Judge, RTC, Br. XXXI, Guimba, Nueva Ecija, G.R. No. 78173, October 26, 1992 | 2. Implied Trusts (Art. 1447 - 1457) — b. Constructive Trusts — Acquisition of property through mistake or fraud (Art. 1456) | |
| 6 | Spouses Aboitiz v. Spouses Po, citing Hortizuela v. Tagufa, G.R. Nos. 208450 & 208497, June 5, 2017 | 2. Implied Trusts (Art. 1447 - 1457) — b. Constructive Trusts — Reconveyance | |
| 7 | Gatmaytan and Valdellon v. Misibis Land, Inc., G.R. No. 222166, June 10, 2020 | 2. Implied Trusts (Art. 1447 - 1457) — b. Constructive Trusts — Prescriptive period to file reconveyance | |
| 8 | Heirs of Tulauan v. Mateo, G.R. No. 248974, September 7, 2022 | 2. Implied Trusts (Art. 1447 - 1457) — b. Constructive Trusts — Prescriptive period to file reconveyance | |
| 9 | GSIS v. Santiago, citing Adille v. CA, G.R. No. 155206, October 28, 2003 | 2. Implied Trusts (Art. 1447 - 1457) — b. Constructive Trusts — Prescriptive period to file reconveyance |
Notes on the syllabus. (1) Torbela v. Rosario is given in the list as G.R. No. 140428; the decision is reported at G.R. Nos. 140528 & 140553, December 7, 2011. (2) The Misibis Land case is captioned Gatmaytan and Valdellon v. Misibis Land, Inc. — Valdellon is the second of two petitioners. The digests use the reported citations. (3) Torbela is assigned under resulting trusts (Art. 1451), but the Court characterised the arrangement as an express trust on the strength of Dr. Rosario's written acknowledgment — treat it as analogous to Art. 1451 rather than a direct application, and see the Syllabus Note in that digest.
Study Notes
Express or implied — and why it matters. An express trust is created by the intention of the trustor or the parties; an implied trust arises by operation of law (Art. 1441). The consequences diverge sharply on proof and on prescription:
| Express trust | Implied trust | |
|---|---|---|
| Proof over immovables | Cannot rest on parol evidence — Art. 1443 requires a writing | May be proved orally, but the evidence must be clear and convincing |
| Prescription | Does not run until the trustee repudiates and the beneficiary knows of it | 10 years from registration/issuance of title (or from discovery of the fraud) |
Cañezo is the cleanest statement of the proof rule and Torbela of the repudiation rule.
Article 1456 is the workhorse of the second half. Property acquired through mistake or fraud makes the acquirer a trustee of an implied (constructive) trust for the benefit of the true owner. That is the doctrinal basis for the action for reconveyance in Aboitiz v. Po, which — citing Hortizuela v. Tagufa — stresses that reconveyance does not attack the decree of registration; it is an action in personam compelling the registered owner to transfer what he holds for another.
The prescription questions are where these cases actually fight. Ten years from registration is the default (Aboitiz), but three qualifications run through the assigned list: the period runs from actual discovery of the fraud where registration gave no real notice (GSIS v. Santiago, following Adille); it does not run at all where the underlying conveyance is void, since Art. 1410 makes that action imprescriptible (Heirs of Tulauan); and a plaintiff in possession may sue to quiet title at any time, while one out of possession faces the ordinary periods (Gatmaytan and Valdellon).