GR 127141; (April, 2003) (Digest)
G.R. No. 127141 ; April 30, 2003
SPOUSES EMMANUEL LANTIN and MELANIE LANTIN, petitioners, vs. THE HONORABLE COURT OF APPEALS (FIRST DIVISION) and the SPOUSES ROLAND B. BELTRAN and MA. VICTORIA REYES-BELTRAN, respondents.
FACTS
Petitioners, the Spouses Lantin, were former lessees of a house owned by Esperanza Reyes. They vacated the premises on March 19, 1994, but retained the key until March 30, 1994. Upon termination of the lease, Reyes deducted various amounts, including P1,180.60 for water and homeowners’ association dues, from the Lantins’ security deposit and refunded the balance. Reyes subsequently leased the property to respondents, the Spouses Beltran, who moved in on April 23, 1994. The Beltrans later discovered and paid several unpaid utility bills, including a water bill for March 1994, to avoid disconnection. They demanded reimbursement from the Lantins, who refused.
The Beltrans filed a collection case before the Metropolitan Trial Court (MeTC), which dismissed the complaint, ruling the Lantins had already paid the dues to Reyes. The Regional Trial Court (RTC) affirmed this decision. The Court of Appeals (CA) reversed the RTC, ordering the Lantins to reimburse the Beltrans P1,587.90 for the water and association dues paid for March 1994, but denied claims for other bills. The Lantins elevated the case to the Supreme Court.
ISSUE
Whether the petitioners are liable to reimburse the respondents for the water consumption bill for March 1994.
RULING
Yes, the petitioners are liable for reimbursement, but the amount is modified. The Supreme Court affirmed the CA with modification, reducing the reimbursable amount to P1,062.90. The legal foundation is Article 1236 of the Civil Code, which allows a person who pays for another to demand reimbursement, provided the payment benefited the debtor. The Court found that the petitioners, having occupied the leased premises until March 19 and retained constructive possession via the key until March 30, were obligated to pay for the water consumption for March 1994. The payment by the respondents benefited the petitioners by relieving them of this very obligation.
However, the Court corrected the CA’s computation. The receipt from the homeowners’ association showed the respondents paid P1,062.90 for March 1994 water consumption and a separate P525.00 for April 1994 association dues. Since the petitioners had no obligation for April, reimbursement was warranted only for the March water bill of P1,062.90. The Court also imposed 12% annual interest on the amount from the finality of the decision until full payment.