G.R. No. 170498, January 9, 2013, 688 SCRA 225
Metrobank deposited the AMC checks to Ayala Lumber and Hardware’s account; because of Chua’s control over AMC’s operations, Metrobank assumed that the checks payable to AMC could be deposited to Ayala Lumber and Hardware’s account.
Ayala Lumber and Hardware had no right to demand and receive the checks that were deposited to its account; despite Chua’s control over AMC and Ayala Lumber and Hardware, the two entities are distinct, and checks exclusively and expressly payable to one cannot be
deposited in the account of the other.
In its fourth-party complaint, Metrobank claims that Chua’s estate should reimburse it if it becomes liable on the checks that it deposited to Ayala Lumber and Hardware’s account.
Whether or not Ayala Lumber must return the amount of said checks to Metrobank.
Metrobank acted in a manner akin to a mistake when it deposited the AMC checks to Ayala Lumber and Hardware’s account because it assumed that the checks payable to AMC could be deposited to Ayala Lumber and Hardware’s account. This disjunct created an obligation on the part of Ayala Lumber and Hardware, through its sole proprietor, Chua, to return the amount of these checks to Metrobank.
This fulfills the requisites of solutio indebiti. Metrobank’s fourth-party complaint falls under the quasi-contracts enunciated in Article 2154 of the Civil Code. Article 2154 embodies the concept “solutio indebiti” which arises when something is delivered through mistake to a person who has no right to demand it. It obligates the latter to return what has been received through mistake. Solutio indebiti, as defined in Article 2154 of the Civil Code, has two indispensable requisites: first, that something has been unduly delivered through mistake; and second, that something was received when there was no right to demand it.
* Case digest by Neah Hope Bato, LLB-1, Andres Bonifacio Law School, SY 2017-2018