ANDRES VS MHTC

GR NO. 82670 September 15,1989

Facts:
 Facet purchased some merchandise from
IWA and paid thru to the PNB account of
IWA.
 The transfer was delayed due to an error.
 Unaware that IWA had already received the
money, Mantrust transferred another
payment to different bank.
 Thus, Mantrust asked IWA to return the
second payment but the latter refused to do
so.
 IWA contended that the second transfer was
negligence on the part of Mantrust.
Issue:

Whether or not IWA was unjustly enriched

because of the erroneous second transfer?
Ruling:
 There was a mistake, not negligence, in the
second remittance.

 Art. 2154 of the Civil Code provides that: If

something received when there is no right to
demand it, and it was unduly delivered through
mistake, the obligation to return it arises.
PUYAT & SONS VS CITY OF
MANILA
GR NO. L-17447 April 30, 1963
Facts:
 Puyat and Sons paid their tax to the City
Treasurer of Manila not knowing that they
are exempt from such, pursuant to an
ordinance.

 After learning about the ordinance, Puyat

asked for refund of the tax.

 However, the City Treasurer denied the

requested refund.
Issue:

Whether or not the defendant is obliged to

refund the amount which the plaintiff paid
Ruling:
 Yes. Puyat is exempted from paying the tax,
hence it was clearly an error or mistake which
makes it fall under Art.2154 of solutio indebiti.

 The obligation to refund the tax arises.

CINCO VS CANONOY
GR NO. L-33171 May 31, 1979
Facts:
 Cinco filed a complaint against the driver
and the operator of a jeepney because of a
vehicular accident.

 Subsequently, Cinco filed a criminal case

against the driver.

 Private respondents moved to suspend the

civil action pending the final determination
of the criminal suit.
Issue:

Whether or not there can be an independent civil

action for damage to property during the
pendency of the criminal action
Ruling:
 Yes. The nature and character of Cinco’s action
was quasi-delictual.

 Section 3, Rule 111 of the Rules of Court

provides that: In the cases provided in Articles
32, 33, 34 and 2176 of the Civil Code of the
Philippines, the independent civil action may be
brought by the offended party. It shall proceed
independently of the criminal action and shall
require only a preponderance of evidence.
NAPOCOR VS CA
GR NO. L-124378 March 8, 2005
Facts:
 Petitioner built and operated the Agus
Regulation Dam and maintains a normal
maximum level of water.
 In 1976, respondents fishponds and other
improvements were washed away when the
water level of the lake escalated.
 Respondents filed an action for damages,
alleging that the negligence and
inexperience of NPC’s employees were the
proximate cause of damage.
 NPC denied the allegation and refused to
compensate the respondents.
Issue:

Whether or not NPC is liable for damages

Ruling:
 Yes. The doctrine of res ipsa loquitor is proper
in this case. In the absence of any clear
explanation on what other factors could have
explained the flooding in the neighboring
properties of the dam, it is fair to reasonably
infer that the incident happened because of
want of care on the part of NPC.
JIMENEZ VS CITY OF
MANILA
GR NO. L-71049 May 29, 1987
Facts:
 Petitioner bought went to Sta. Ana Public
Market which was flooded by dirty water.
 Consequently, petitioner stepped on an
uncovered drainage opening causing a 4-
inch rusty nail to penetrate his leg, fell sick
and was unable to supervise his business for
long time.
 He sued the City of Manila and the
administrator of the market.
Issue:

Whether or not the City of Manila are jointly and

solidarily liable with the administrator
Ruling:
 Yes. The negligence of the city is the proximate
cause of the injury. Asiatec and the City are
joint tortfeasors and are solidarily liable.
 Art. 2189 of the Civil Code provides that:
Provinces, cities, and municipalities shall be
liable for damages for the death of or injuries
suffered by any person by reason of defective
conditions of roads, streets, and other public
works under their control or supervision.
SANCHEZ VS RIGOS
GR NO. L-25494 June 4, 1972
Facts:
 Rigos executed an “Option to purchase”
stipulating that he will sell his parcel of land
to Sanchez within 2 years from the
stipulated date.
 Within 2 years, Sanchez deposited the sum
of money for the purchase of the said parcel
of land but Rigos refused to sell his land.
 Rigos contended that the contract was
unilateral promise to sell and the same
being unsupported by any valuable
consideration by force of the Civil Code,
therefore it is null and void.
Issue:

Whether or not there was a contract to buy and

sell between the parties or only a unilateral
promise to sell?
Ruling:
 The instrument executed is not a "contract to
buy and sell," but merely granted plaintiff an
"option" to buy.
 Rigor can withdraw his offer anytime he want.
 However, pending notice of its withdrawal, his
accepted promise partakes, however, of the
nature of an offer to sell which, if accepted,
results in a perfected contract of sale.