G.R. No. 199451 , August 15, 2018
Iris Rodriguez, Petitioner, v. Your Own Home Development Corporation (YOHDC), Respondent.

FACTS

This case originated from a housing project where petitioner Iris Rodriguez’s husband, Tarcisius, was the project manager. Tarcisius negotiated to buy land from Rosa Rosillas for P1.2 million but misrepresented to YOHDC that the price was P4 million. YOHDC issued four checks payable to Rosillas and the surveyor, Engr. Senen Delos Reyes. Instead of delivering the checks, the Rodriguez spouses deposited them into their personal bank accounts. YOHDC discovered the fraud after confirming with Rosillas and Delos Reyes that they never received the checks. YOHDC demanded reimbursement from Tarcisius and, after failed negotiations, pursued a claim with the banks, leading to BPI debiting the Rodriguez spouses’ account to reimburse YOHDC.
The Rodriguez spouses then filed a complaint for damages. The Regional Trial Court (RTC) dismissed the case against most defendants but ordered YOHDC to pay Iris Rodriguez P424,000. The RTC based this on an alleged admission in Delos Reyes’ Answer that he received P424,000 from the check proceeds, applying the principle against unjust enrichment. The Court of Appeals (CA) reversed the RTC, finding no basis for the award. Iris Rodriguez elevated the case to the Supreme Court via a Petition for Review.

ISSUE

Whether the Court of Appeals erred in reversing the RTC’s decision ordering YOHDC to reimburse Iris Rodriguez the amount of P424,000.

RULING

The Supreme Court denied the petition and affirmed the CA decision. The core legal issue was the proper application of the principle against unjust enrichment under Article 22 of the Civil Code. The Court held that this principle applies only when no other provision of law governs the parties’ relations. Here, the relationship between the parties was governed by specific provisions on quasi-delict and solutio indebiti.
The RTC’s reliance on an alleged admission in Delos Reyes’ Answer was erroneous. The document referenced was an unauthenticated private document, and its execution was not duly proven as required by the Rules of Evidence. In contrast, YOHDC presented credible evidence, including a duly notarized affidavit from Delos Reyes stating he never received the checks, and payment receipts showing he had already been separately paid for his services. The Supreme Court emphasized that notarized documents carry evidentiary weight and are prima facie evidence of their execution.
Furthermore, the Court found that Iris Rodriguez, who participated in depositing the checks intended for third parties into her personal account, could not invoke equity or the principle against unjust enrichment. One who comes to court must do so with clean hands. Since the funds were obtained through her husband’s fraudulent misrepresentation, she had no right to retain them. The debit made by BPI to reimburse YOHDC was therefore proper. The claim for reimbursement had no legal basis, as YOHDC was rightfully restored to the amount it lost due to the fraud.