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Metropolitan Bank & trust Company, Inc. vs. The Board of Trustees
of Riverside Mills Corp. Provident and Retirement Fund, et al., G.R.
No. 176959, September 8, 2010
A trust is a fiduciary relationship with respect to property which
involves the existence of equitable duties imposed upon the holder of
the title to the property to deal with it for the benefit of another. A
trust is either express or implied. Express trusts are those which the
direct and positive acts of the parties create, by some writing or deed,
or will, or by words evincing an intention to create a trust.
Here, an express trust was created to provide retirement benefits
to the regular employees of RMC. RMC retained legal title to the Fund
but held the same in trust for the employees-beneficiaries. Employees
trusts or benefit plans are intended to provide economic assistance to
employees upon the occurrence of certain contingencies, particularly,
old age retirement, death, sickness, or disability. They give security
against certain hazards to which members of the Plan may be exposed.
They are independent and additional sources of protection for the
working group and established for their exclusive benefit and for no
other purpose. Here, while the plan provides for a reversion of the fund
to RMC, this cannot be done until all the liabilities of the plan have
been paid. And when RMC ceased operations in 1984, the fund became
liable for the payment not only of the benefits of qualified retirees at
the time of RMCs closure but also of those who were separated from
work as a consequence of the closure.
5. Implied trust
Heirs Pedro De Guzman vs. Angelina Perona and Heirs of Rosauro
De Guzman, Bataan Development Bank and Republic Planters
Bank, G.R. No. 152266, July 2, 2010
Petitioners submission that respondents merely hold the title to
the properties in trust for their predecessor Pedro is without merit.
Pedro failed to prove by clear and convincing evidence that the
spouses Rosauro and Angelina managed, through fraud, to have the
real properties subject of this case registered in their name. In the
absence of fraud, no implied trust was established between Pedro and
the spouses Rosauro and Angelina under Article 1456 of the New Civil
Code.
6. Trusts
Estate of Margarita D. Cabacungan, represented by Luz Laigo-Ali vs.
Marilou Laigo, et al. ;G.R. No. 175073. August 15, 2011
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