Case Brief: Camacho vs. Municipality of Baliuag

G.R. No. 9363    November 24, 1914

Albino Camacho


Municipality of Baliuag, Province of Bulacan



A land originally owned by municipal government was claimed by central government and was sold at a public auction, to which Camacho was the highest bidder. Title was issued in his name. Notwithstanding the sale, the municipality continued to occupy the land and collected rents therefrom.

Both plaintiff and defendant had their own set of facts. However, SC decided that by virtue of the parol evidence rule, Camacho actually acquired the land in his name while acting in a fiduciary capacity for the Municipality.



Whether or not the court can compel Camacho to reconvey the land to Municipality, even in the presence of the title in Camacho’s name.



Yes. Camacho must reconvey the land to the municipality.

There have been a number of cases in which a title to real property was acquired by a person in his own name while acting in a fiduciary capacity, and who afterwards sought to take advantage of the confidence reposed in him by claiming the ownership of the property for himself. This court has invariably held such evidence competent as between the fiduciary and the cestui que trust.

What judgment ought to be entered in this case? Municipality must be absolved from the complaint. Munipality does not ask for a cancellation of the deed. On the contrary, the deed is relied upon to supplement the oral evidence showing that the title to the land is in the Municipality. The proper procedure in such a case, so long as the rights of innocent third persons have not intervened, is to compel a conveyance to the rightful owner.


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