G.R. No. 152411 September 29, 2004

FACTS:

The University of the Philippines (UP) decided to construct an integrated system of research organization known as the Research Complex. As part of the project, laboratory equipment and furniture were purchased for the National Institute of Biotechnology and Applied Microbiology (BIOTECH). Ferdinand E. Marcos Foundation (FEMF) came forward and agreed to fund the acquisition of the laboratory furniture, including the fabrication thereof.  

PHILAB was chosen to fabricate the laboratory furniture and deliver the same to BIOTECH.  It made partial deliveries of office and laboratory furniture to BIOTECH after having been duly inspected by their representatives and FEMF Executive Assistant Lirio. However, PHILAB failed to submit the contract for the installation of laboratory furniture to BIOTECH. In 1984, PHILAB submitted to BIOTECH Invoice No. 01643 in the amount of P702,939.40 for the final payment of laboratory furniture. There was, however, no response from the FEMF.

When President Marcos was ousted from office during the February 1986 EDSA Revolution, PHILAB wrote to President Aquino asking her help to secure the payment of the amount due from the FEMF. The PCGG requested for the MOA, but, PHILAB and FEMF did not execute any contract regarding the fabrication and delivery of laboratory furniture to BIOTECH.

Exasperated, PHILAB filed a complaint for a sum of money and damages against UP.  UP denied liability and alleged that PHILAB had no cause of action against it because it was merely the donee/beneficiary of the laboratory furniture in the BIOTECH; and that the FEMF, which funded the project, was liable to the PHILAB. 

The trial court rendered judgment dismissing the complaint. 

The CA reversed and set aside the decision of the RTC and held that although UP did not bind itself to pay for the laboratory furniture; nevertheless, it is liable to PHILAB under the maxim: “No one should unjustly enrich himself at the expense of another.”

ISSUES: 

1. Whether UP is liable for the final payment of laboratory furniture to PHILAB.

2. Whether CA is correct in holding the petitioner liable for the claim of the respondent based on the maxim that no one should enrich itself at the expense of another

HELD:

1. NO. The respondent is not entitled to its claim against the petitioner.

While the respondent is not privy to the MOA executed by the petitioner and FEMF, but, based on the records, an implied-in-fact contract of sale was entered into between the respondent and FEMF. A contract implied in fact is one implied from facts and circumstances showing a mutual intention to contract. It arises where the intention of the parties is not expressed, but an agreement in fact creating an obligation. It is a contract, the existence and terms of which are manifested by conduct and not by direct or explicit words between parties but is to be deduced from conduct of the parties, language used, or things done by them, or other pertinent circumstances attending the transaction. To create contracts implied in fact, circumstances must warrant inference that one expected compensation and the other to pay. An implied-in-fact contract requires the parties’ intent to enter into a contract; it is a true contract. The conduct of the parties is to be viewed as a reasonable man would view it, to determine the existence or not of an implied-in-fact contract. The totality of the acts/conducts of the parties must be considered to determine their intention. 

The respondent was aware, from the time Padolina contacted it for the fabrication and supply of the laboratory furniture until the go-signal was given to it to fabricate and deliver the furniture to BIOTECH as beneficiary, that the FEMF was to pay for the same. The respondent knew that the petitioner was merely the donee-beneficiary of the laboratory furniture and not the buyer; nor was it liable for the payment of the purchase price thereof.

2. NO.  Unjust enrichment claims do not lie simply because one party benefits from the efforts or obligations of others, but instead it must be shown that a party was unjustly enriched in the sense that the term unjustly could mean illegally or unlawfully. To substantiate a claim for unjust enrichment, the claimant must unequivocally prove that another party knowingly received something of value to which he was not entitled and that the state of affairs are such that it would be unjust for the person to keep the benefit.

Article 22 of the New Civil Code reads:

Every person who, through an act of performance by another, or any other means, acquires or comes into possession of something at the expense of the latter without just or legal ground, shall return the same to him.

In order that accion in rem verso may prosper, the essential elements must be present: (1) that the defendant has been enriched, (2) that the plaintiff has suffered a loss, (3) that the enrichment of the defendant is without just or legal ground, and (4) that the plaintiff has no other action based on contract, quasi-contract, crime or quasi-delict. An accion in rem verso is considered merely an auxiliary action, available only when there is no other remedy on contract, quasi-contract, crime, and quasi-delict. If there is an obtainable action under any other institution of positive law, that action must be resorted to, and the principle of accion in rem verso will not lie

The essential requisites for the application of Article 22 of the New Civil Code do not obtain in this case. The respondent had a remedy against the FEMF via an action based on an implied-in-fact contract with the FEMF for the payment of its claim. The petitioner legally acquired the laboratory furniture under the MOA with FEMF; hence, it is entitled to keep the laboratory furniture.

G.R. No. 210641, March 27, 2019

FACTS:

The parties entered into a Contract of Lease whereby DPRC (petitioner) was obliged to pay monthly rentals of P75,357.74 for the land and P33,310.46 for the building. In 1998, MIAA passed Resolution No. 98-30 which increased the rentals. DPRC protested in writing to [respondent MIAA] the increased rentals and the computation on the ground that it was decreed without prior notice. However, it also signified its intention to comply in good faith with the terms and conditions of the lease contract by paying the amount charged.

DPRC stopped paying the increased rental rate but continued paying the original rental rate prescribed in the lease contract. The decision to stop paying the increased rental rate was based on the [Court’s] Decision in the case of Manila International Airport Authority vs. Air span Corporation. DPRC demanded for the refund of its overpayment in the amount of P9,593,179.87. In 2008, DPRC filed a Complaint for “Collection of Sums of Money”.

RTC decided in favor of petitioner DPRC ordering for the payment of the principal amount plus 12% per annum legal interest computed from the time of the extrajudicial demand.

The CA affirmed the RTC’s Decision but with a modification as to the amount. The CA found that the liability of respondent MIAA to petitioner DPRC for overpaid monthly rentals was in the nature of a quasi-contract of solutio indebiti. The CA held that by reason of the six (6) years prescriptive period, DPRC lost its right to recover the amount of P5,753,536.82 paid during the period from December 11, 1998 to December 5, 2002.

ISSUE:
Whether the modification of MIAA’s liability from the full amount of P9,593,179.87 to just P3,839,643.05 plus legal interest on the ground of application of the six-year prescriptive period governing the quasi-contract of solutio indebiti is correct.

HELD: 

NO. In order to establish the application of solutio indebiti in a given situation, two conditions must concur: (1) a payment is made when there exists no binding relation between the payor who has no duty to pay, and the person who received the payment, and (2) the payment is made through mistake, and not through liberality or some other cause. The Court finds that the essential requisites of solutio indebiti are not present – there exists a binding relation between petitioner DPRC and respondent MIAA. The parties are mutually bound to each other under a Contract of Lease, hence, having the juridical relationship of a lessor-lessee, it cannot be said that the overpayment of monthly rentals was made when there existed no binding juridical tie or relation. 

For the concept of solutio indebiti to apply, the undue payment must have been made by reason of either an essential mistake of fact or a mistake in the construction or application of a doubtful or difficult question of law. DPRC deliberately made the payments in accordance with respondent MIAA’s Resolution No. 98-30, albeit under protest.

Considering that petitioner DPRC’s cause of action is not based on a quasi-contract and is instead founded on the enforcement of a contract, the CA erred in applying Article 1145(2) of the Civil Code in the instant case. Instead of the prescriptive period of six years for quasi-contracts, it is Article 1144 of the Civil Code that finds application in the instant case. This Article provides that an action based on a written contract must be brought within 10 years from the time the right of action accrues.

G.R. No. 202039, August 14, 2019

FACTS:

Angelita Keppel left the Philippines to work in Germany as a nurse. She was first married to Reynaldo Macaraig but separated due to her infidelity. Angelita and Georg (also married) continued their relationship.  In 1986, Angelita became a naturalized German citizen. 

Angelita obtained a divorce decree on her first marriage. Shortly thereafter, Angelita and Georg got married in Germany and had a daughter, whom they named Liselotte. In 1991, Angelita and Georg entered into an agreement for the complete separation of their properties. Angelita decided to return and settle permanently in the Philippines in 1992.

In 1996, Angelita filed the instant petition for annulment of marriage on the ground of Georg’s alleged psychological incapacity.  Georg opposed the petition, insisting that the court should only issue a decree of legal separation with the consequent division of their properties and determination of Liselotte’s custody.

RTC rendered judgment declaring the marriage of Angelita and Georg null and void. 

The CA reversed and dismissed the complaint on the ground that Angelita failed to prove the allegations in her complaint because – 

1. she did not present the original of her divorce decree from Reynaldo Macaraig
2. she did not also prove the German law that capacitated her to marry Georg
3. evidence was insufficient to prove that either of the parties herein had been psychologically incapacitated to comply with essential marital obligation

ISSUES: 

1. Whether Angelita’s petition for annulment of marriage under the Philippine law is proper

2. Whether the marriage between Angelita and Georg is null and void due to psychological incapacity.

HELD: 

1. NO. Under the Nationality Principle, the petitioner cannot invoke Article 36 of the Family Code unless there is a German law that allows her to do so. Angelita’s petition for annulment of marriage under the Philippine law is improper   because of both Georg and Angelita being German citizens, not Filipinos, at the time of the filing thereof. Based on the Nationality Principle, which is followed in this jurisdiction, and pursuant to which laws relating to family rights and duties, or to the status, condition and legal capacity of persons are binding upon citizens of the Philippines, even though living abroad, it was the pertinent German law that governed. In short, Philippine law finds no application herein as far as the family rights and obligations of the parties who are foreign nationals are concerned. 

Firstly, what governs the marriage of the parties is German, not Philippine, law, and this rendered it incumbent upon Angelita to allege and prove the applicable German law. Our courts do not take judicial notice of foreign laws; hence, the existence and contents of such laws are regarded as questions of fact, and, as such, must be alleged and proved like any other disputed fact. Proof of the relevant German law may consist of any of the following, namely: (1) official publications of the law; or (2) copy attested to by the officer having legal custody of the foreign law. If the official record is not kept in the Philippines, the copy must be (a) accompanied by a certificate issued by the proper diplomatic or consular officer in the Philippine foreign service stationed in the foreign country in which the record is kept; and (b) authenticated by the seal of his office. Angelita did not comply with the requirements for pleading and proof of the relevant German law.

Second, the remedy of annulment of the marriage due to psychological incapacity afforded by Article 36 of the Family Code might not be available for her. In the absence of a showing of her right to this remedy in accordance with German law, therefore, the petition should be dismissed.

2. Assuming the remedy was proper, the petitioner did not prove the respondent’s psychological incapacity. Psychological incapacity under Article 36 of the Family Code contemplates an incapacity or inability to take cognizance of and to assume basic marital obligations, and is not merely the difficulty, refusal, or neglect in the performance of marital obligations or ill will. The disorder consists of: (a) a true inability to commit oneself to the essentials of marriage; (b) the inability must refer to the essential obligations of marriage, that is, the conjugal act, the community of life and love, the rendering of mutual help, and the procreation and education of offspring; and (c) the inability must be tantamount to a psychological abnormality. Proving that a spouse did not meet his or her responsibility and duty as a married person is not enough; it is essential that he or she must be shown to be incapable of doing so because of some psychological illness.

The petitioner presented no evidence to show that the anti-social behavior manifested by both parties had been grave, and had existed at the time of the celebration of the marriage as to render the parties incapable of performing all the essential marital obligations provided by law.

G.R. No. 250520. May 05, 2021

FACTS:

Petitioner Francis Luigi G. Santos (petitioner) filed a petition for change of name under Rule 103 of the Rules of Court seeking to change his surname from “Santos” to “Revilla” in his Certificate of Live Birth. Lovely Guzman and Bong Revilla (Francis’ parents) were never married, therefore, Francis’ Certificate of Live Birth did not bear the Revilla surname and his father was marked as unknown. However, Bong Revilla executed an Affidavit of Acknowledgment recognizing the petitioner as his son. In 1999, Lovely Guzman married Patrick Joseph P. Santos (Patrick Santos), who, in turn, legally adopted petitioner. Thus, petitioner’s name was changed from “Francis Luigi Guzman” to “Francis Luigi G. Santos.” 

The petitioner filed the instant petition in order to “avoid confusion,” “to show [his] sincere and genuine desire to associate himself to [Bong Revilla] and to the Revillas,” and to ensure that his records show his true identity as Bong Revilla’s son.

The RTC denied the petition and held that a change of name was not a matter of right and could be granted only for compelling reasons. 

The CA affirmed the decision of the RTC and held that allowing a change of name would create more confusion as to petitioner’s status and filiation given that he had already been legally adopted by Patrick Santos. That the corrections sought involved substantial amendments to petitioner’s birth certificate, as allowing a change in surname from “Santos” to “Revilla” would constitute a change in his status from “legitimate” to “illegitimate.” The CA held that petitioner should have availed himself of the adversarial proceeding under Rule 108 for cancellation and/or correction of entries rather than the summary proceeding under Rule 103 for change of name.

ISSUES:

1. Whether Rule 108 rather than Rule 103 applies

2. Whether the CA correctly denied the petition to change name

HELD:

1. NO. Petitioner correctly availed of a Rule 103 proceeding to effect the desired change.
It is a threshold principle that the nature of a proceeding is determined by the allegations in the petition and the ultimate reliefs sought. In the instant case, it is apparent that petitioner does not seek to correct any clerical or substantial error in his birth certificate or to effect any changes in his status as an adopted child of Patrick Santos. As such, neither Rule 108 nor R.A. 9048 as amended applies. Rather, the petition is unequivocal that petitioner merely desires to change and replace his surname “Santos” with the surname “Revilla” in accordance with Hernandez in order to “avoid confusion,”51 “to show [his] sincere and genuine desire to associate himself to [Bong] Revilla[,] Jr. and to the Revillas, and to show that he accepts and embraces his true identity. These allegations show that petitioner ultimately seeks to “alter the ‘designation by which he is known and called in the community in which he lives and is best known'”55 and not to effect any clerical or substantial corrections. Thus, he properly availed himself of the procedure prescribed under Rule 103.

2. YES. No similar compelling reason was alleged nor proved in this case. A sincere desire to associate oneself to a certain person or family, without more, does not justify a change of surname. The following have been considered valid grounds for change of name: “(a) when the name is ridiculous, dishonorable or extremely difficult to write or pronounce; (b) when the change results as a legal consequence, as in legitimation; (c) when the change will avoid confusion; (d) when one has continuously used and been known since childhood by a Filipino name, and was unaware of alien parentage; (e) a sincere desire to adopt a Filipino name to erase signs of former alienage, all in good faith and without prejudicing anybody; and (f) when the surname causes embarrassment and there is no showing that the desired change of name was for a fraudulent purpose or that the change of name would prejudice public interest.”

The use of the surname “Revilla” would create further confusion rather than avoid it, given that: (1) petitioner has never legally used the name “Revilla” despite having been acknowledged in 1996; (2) he was legally adopted by Patrick Santos in 2001; (3) he has used the name “Santos” for all documentary purposes since his adoption; (4) although he is publicly known to be the son of Bong Revilla, he is known by his peers as “Luigi Santos”; (5) even after a change of surname, Patrick Santos shall continue to be the father named in his birth certificate; and (5) he only began using the surname “Revilla” when he entered show business.

Second. While petitioner may factually identify and associate with his biological father and his family, he remains to be the legitimate son of Patrick Santos by virtue of the adoption. The latter and not the former is thus his true legal identity.

Finally, it bears emphasis that a change of name is a privilege and not a matter of right. It is addressed to the sound discretion of the court.