GR 82670; (September, 1989) (Digest)
G.R. No. 82670 September 15, 1989
DOMETILA M. ANDRES, doing business under the name and style “IRENE’S WEARING APPAREL,” petitioner, vs. MANUFACTURERS HANOVER & TRUST CORPORATION and COURT OF APPEALS, respondents.
FACTS
Petitioner Dometila Andres, operating as “Irene’s Wearing Apparel,” received a $10,000 remittance from her foreign buyer, Facets Funwear, Inc., via the Philippine National Bank on August 28, 1980. Due to communication delays, Facets, unaware the payment had been completed, instructed its bank to re-route the same payment through a different channel. Consequently, private respondent Manufacturers Hanover & Trust Corporation, acting on this amended instruction, caused a second $10,000 remittance to be delivered to petitioner through the Philippine Commercial and Industrial Bank on September 11, 1980. Upon discovery of the duplication, private respondent’s account was debited by its correspondent bank, leading it to demand reimbursement from petitioner, who refused.
ISSUE
Whether private respondent has the right to recover the second $10,000 remittance delivered to petitioner.
RULING
Yes. The Supreme Court affirmed the Court of Appeals’ application of the principle of solutio indebiti under Article 2154 of the Civil Code. For this provision to apply, two requisites must concur: (1) the payment was made when there was no right to demand it, and (2) it was unduly delivered through an essential mistake of fact. Both requisites are present. Private respondent had no obligation to make the second payment, as the purchase price had already been fully settled by the first remittance. The second payment was made due to a mistake of fact—the lack of knowledge that the initial payment had already been received by petitioner. The Court emphasized that solutio indebiti is a concrete application of the principle against unjust enrichment. Petitioner’s retention of the second sum constitutes unjust enrichment at the expense of private respondent, who suffered the loss. The Court rejected petitioner’s argument that the loss should be borne by the party whose negligence caused it, holding that a specific statutory provision (Article 2154) prevails over general equitable principles. The action was also filed well within the prescriptive period for quasi-contracts.