GR L 36249; (March, 1985) (Digest)
G.R. No. L-36249 March 29, 1985
ANIANO OBAÑA, petitioner, vs. THE COURT OF APPEALS AND ANICETO SANDOVAL, respondents.
FACTS
Aniceto Sandoval, owner of a rice mill, agreed to sell 170 cavans of rice to Chan Lin. The agreement stipulated delivery at petitioner Aniano Obaña’s store in San Fernando, La Union, with payment to be made there to Sandoval’s representative. The rice was delivered as agreed, but upon arrival, Chan Lin disappeared without paying Sandoval’s truck driver. The driver then demanded payment from Obaña, who refused, claiming he had already purchased the same rice from Chan Lin at a lower price and had paid him.
Sandoval filed a replevin suit against Obaña. The Municipal Court ruled partially for Sandoval, but the Court of First Instance dismissed the complaint. The Court of Appeals reversed, ordering Obaña to return the rice or pay its value. Obaña appealed to the Supreme Court, arguing a perfected sale occurred between Sandoval and Chan Lin, transferring ownership.
ISSUE
Whether Obaña acquired ownership of the rice from Chan Lin, thereby precluding Sandoval’s recovery in an action for replevin.
RULING
No. The Supreme Court affirmed the Court of Appeals’ decision, albeit on a different legal basis. Initially, a sale was perfected between Sandoval and Chan Lin upon their agreement on the object and price. Ownership could have transferred to Chan Lin upon delivery at the stipulated place. However, Obaña’s own testimony revealed that three days after the delivery, Chan Lin, accompanied by Sandoval’s driver, returned to Obaña, requested the rice back, and repaid Obaña the purchase price of P5,600. This act constituted a voluntary rescission of the sale between Chan Lin and Obaña. Consequently, Obaña was divested of any claim to the rice. Since Chan Lin, according to Obaña’s testimony, intended to return the rice to Sandoval, and Sandoval’s driver denied any actual return occurred, Obaña could not retain the property. Applying the principle against unjust enrichment under Article 22 of the Civil Code, Sandoval, as the original owner who never received payment, was legally and equitably entitled to recover the rice or its value from Obaña, who no longer had a rightful claim after being reimbursed.