Venzon v Rural Bank of Buenavista, G.R. No. 178031, August 28, 2013 CASE DIGEST

 Facts:

    The petitioner filed to nullify the foreclosure proceedings and the Tax Declaration issued in the name of the respondent. The petitioner alleged that in 1983 she and her late spouse obtained a Php 5,000.00 loan from the respondent against a mortgage on their house and lot; that she was able to pay Php 2,300.00, thus leaving an outstanding balance of only Php 2,300.00; that sometime in March 1987, she offered to pay the said balance in full but was refused by the respondent; that in March 1987, the respondent foreclosed the mortgage and the property was sold at auction and the respondent being the highest bidder; that the foreclosure proceedings are null and void for lack of notice and publication of the sale; and that the petitioner paid the respondent Php 6,000.00 on October 9, 1995, as evidence by an official receipt issued by the respondent. In its answer, the respondent claimed that the petitioner did not make any payment on the loan; that the foreclosure proceedings were regularly done and all requirements were complied with; and that the Php 6,000.00 paid by the petitioner is utterly false.

Issue:

    WoN the petitioner is entitled to a return of the Php 6,000.00 she paid to the respondent?

Ruling:

(solutio indebiti; 2154-2163)

    Yes, the petitioner is entitled to a return of the Php 6,000.00 she paid the respondent.

    While this may not be validly considered as a redemption of her property as the payment was made long after the redemption period had expired, the respondent had no right to receive the amount. If something is received when there is no right to demand it, and it was unduly delivered through mistake, the obligation to return it arises.

Locsin II v Mekeni Food Corporation, G.R. No. 192105, December, 9, 2013 CASE DIGEST

 Facts:

    The respondent offered the petitioner a position in its organization. In addition to a compensation and benefits package, the respondent offered a car plan, under which one-half of the cost of the vehicle is to be paid by the respondent company and the other half to be deducted from the petitioner's salary. The offer was contained in an Offer Sheet. The petitioner began his work on 17 March 2004 and was furnished by the respondent company with a used car valued at Php 280,000.00. The petitioner paid for his share through salary deductions of Php 5,000.00 each month. The petitioner resigned on 25 February 2006, in his resignation letter he made an offer to purchase his service vehicle by paying the outstanding balance thereon. Both parties could not agree on the terms of the proposed purchase, thus the vehicle was returned on 2 May 2006. The petitioner made personal and written follow-ups regarding his unpaid salaries, commissions, benefits, and offer to purchase his service vehicle. The respondent replied that the company car plan benefit applied only to employees who have been with the company for five years; for this reason, the balance that the petitioner should pay on his service vehicle stood at Php 116,380.00 if he opts to purchase the same. On 3 May 2007, the petitioner filed a complaint for the recovery of monetary claims and recovery of monthly salary deductions which were earmarked for his cost-sharing in the car plan.

Issue:

    WoN the salary deductions made on the service vehicle (the car plan) can be considered as rentals?

Ruling:

(Article 1160; 2142)

    No, the salary deductions made on the service vehicle cannot be considered as rentals.

    From the evidence on record, it is seen that the respondent's car plan offered to the petitioner was subject to no other term or condition than that the respondent company shall cover one-half through deductions from his monthly salary. The respondent has not shown by documentary evidence to suggest that if the petitioner failed to completely cover one-half of the cost of the vehicle, then all the deductions from his salary going to the cost of the vehicle will be treated as rentals for his use thereof while working with the respondent company, and shall not be refunded.

Ollendorff v Abrahamson, G.R. No. 13228, September 13, 1918 CASE DIGEST

 Facts:

    The petitioner is engaged in the business of manufacturing ladies' embroidered underwear for export. On the 10th of September 1915, the petitioner and respondent entered into a contract, whereby the respondent entered the employ of the petitioner and worked for him until April 1916. The respondent, on account of ill health, left the petitioner's employ and went to the United States. Some months after, the respondent returned to Manila as the manager of a corporation which turned out the same class of goods as that of the petitioner. The petitioner commenced this action, the purpose of which is to prevent by injunction any further breach of that part of the respondents' contract of employment by which he agreed to not enter into or engage himself directly or indirectly in a similar competitive business to that of the petitioner for a period of five years from the date of the agreement. The respondent argues that the contract is void for being restrictive of trade.

Issue:

    WoN the contract of employment is valid?

Ruling:

(Article 1159; 1305, 1315)

    Yes, the contract of employment is valid.

    If there is one thing more than another which is essential to the trade and commerce of this country, it is the inviolability of a contract deliberately entered into; and to allow a person of mature age, and not impose upon, to enter into a contract, to obtain the benefit of it, and then to repudiate it and the obligation which he has undertaken, is prima facie, at all events, contrary to the interest of any and every country.

    The public policy which allows a person to obtain employment on certain terms understood by and agreed to by him, and to repudiate his contract, conflicts with, and must, to avail the defendant, for some sufficient reason, prevail over, the manifest public policy, which, as a rule, holds him to his bond.

City of Cebu v Sps. Dedamo, G.R. No. 142971, May 2, 2002 CASE DIGEST

 Facts:

    On 17 September 1993, the petitioner filed a complaint for eminent domain against the respondents. The petitioner alleged that it needed the parcels of land for a public purpose. i.e. public roads. The respondents filed a motion to dismiss the complaint because the purpose of which their property was to be expropriated was not for a public purpose but for the benefit of a single private entity. On 14 December 1994, both parties executed an Agreement wherein they declared that they have partially settled the case. According to the agreement, the trial court appointed three commissioners to determine the just compensation of the lots sought to be expropriated. Thereafter, the commissioners submitted their report. Based on this report, the trial court awarded Php 24,865,930.00 to respondents. Petitioners then filed a motion for reconsideration on the ground that the commissioners' report was inaccurate.

Issue:

    WoN the agreement between the parties is valid?

Ruling:

(Article 1159;1305, 1315)

    Yes, the agreement is valid.

    More than anything else, the parties, by a solemn document, freely and voluntarily agreed upon by them, agreed to be bound by the report of the commission and approved by the trial court. The agreement is a contract between the parties. It has the force of law between them and should be complied with in good faith.

    Records show that the petitioner consented to conform with the valuation recommended by the commissioners. It cannot detract from its agreement now and assail correctness of the commissioner's assessment.

Leung Ben v O'Brien, G.R. No. L-13602, April 16, 1918 CASE DIGEST

 Facts:

    An action was instituted by the respondent to recover from the petitioner the sum of Php 15,000.00 alleged to have been lost by the petitioner to the respondent in a series of gambling, banking, and percentage games conducted during the two of three months prior to the institutions of the suit. Petitioner moved to quash the complaint. Petitioner contends that the action to recover money lost at gaming is no such action as contemplated by law. The law requires that there should be a cause of action arising upon a contract, express or implied.

Issue:

    WoN the statutory obligation to restore money won at gaming is an obligation arising from a contract?

Ruling:

(Article 1158)

    Yes, the obligation to restore money won at gaming is an obligation arising from a contract.

    The obligation to return money lost at play has a decided affinity to contractual obligations; and we believe that it could, without violence to the doctrines of civil law, be held that such obligations is an innominate quasi-contract.

Pelayo v Lauron, G.R. No. 4089, January 12, 1909 CASE DIGEST

Facts:

    Petitioner, a physician, filed a complaint against respondents that on or about the 13th of October 1906, at night, he was called to the house of respondents, and upon arrival, he was requested by them to render medical assistance to their daughter-in-law who was about to give birth. It was found necessary, on account of the difficult birth, to remove the fetus by means of forceps and also to remove the after birth. The just and equitable value of the services rendered by the petitioner was Php 500, to which the respondents refuse to pay without alleging any good reason. In answer to the complaint, the respondents denied all the allegations, that their daughter-in-law had died in consequence of the childbirth, she lived with her husband independently and in a separate house, and that her stay was accidental and due to fortuitous circumstances.

Issue:

    WoN the respondents are bound or obligated to pay the fees due to the petitioner?

Ruling:

(Article 1158)

    No, the respondents are not obligated to pay the fees due to the petitioner.

    Obligations are created by law, by contracts, by quasi-contracts, and by illicit acts and omissions or by those in which any kind of fault or negligence occurs.

    The rendering of medical assistance in case of illness is comprised of the mutual obligations to which spouses are bound by way of mutual support.

    The person bound to pay the fees due to the petitioner for the professional services that he rendered to the daughter-in-law of the respondents during her childbirth is the husband of the patient and not her father-in-law and mother-in-law.

    The fact that it was not the husband who called the petitioner and requested his assistance for his wife is no bar to the fulfillment of the said obligation, as the respondents, in view of the imminent danger to which the life of the patient was at that moment exposed, considered that medical assistance was urgently needed, and the obligation of the husband to furnish his wife with the indispensable services of a physician at such critical moments is specially established by the law, as has been, and compliance therewith is unavoidable; therefore, the petitioner, who believes that he is entitled to recover his fees must direct his action against the husband who is under obligation to furnish medical assistance to his lawful wife in such an emergency.