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Metrobank v. Absolute Management Corp., G.R. No. 170498, January 9, 2013, 688 SCRA 225

Metrobank deposited checks payable to AMC into the account of Ayala Lumber and Hardware due to the control that Chua exercised over both corporations. However, AMC and Ayala Lumber are separate legal entities, so Ayala did not have the right to receive checks made out to AMC. Metrobank argued in its fourth-party complaint that Chua's estate should reimburse Metrobank if it becomes liable for depositing the checks into the wrong account. The courts ruled that this constituted a quasi-contract known as solutio indebiti, requiring Ayala to return the amounts received by mistake to Metrobank. As a claim based on a quasi-contract against a deceased person, it should have been filed with the

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434 views3 pages

Metrobank v. Absolute Management Corp., G.R. No. 170498, January 9, 2013, 688 SCRA 225

Metrobank deposited checks payable to AMC into the account of Ayala Lumber and Hardware due to the control that Chua exercised over both corporations. However, AMC and Ayala Lumber are separate legal entities, so Ayala did not have the right to receive checks made out to AMC. Metrobank argued in its fourth-party complaint that Chua's estate should reimburse Metrobank if it becomes liable for depositing the checks into the wrong account. The courts ruled that this constituted a quasi-contract known as solutio indebiti, requiring Ayala to return the amounts received by mistake to Metrobank. As a claim based on a quasi-contract against a deceased person, it should have been filed with the

Uploaded by

Gamar Alih
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© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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TITLE OF THE CASE: Metrobank v. Absolute Management Corp., G.R. No.

170498, January 9, 2013, 688 SCRA 225

LAW:
● Art. 1157. Obligations arise from: (1) Law; (2) Contracts; (3) Quasi-
contracts; (4) Acts or omissions punished by law; and (5) Quasi-delicts.
● Article 2154. 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.

FACTS OF THE CASE:


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.

RTC RULING:
In an order dated May 7, 2004, the RTC denied Metrobank’s motion. It likewise
denied Metrobank’s motion for reconsideration in an order dated July 7, 2004.
The RTC categorized Metrobank’s allegation in the fourth-party complaint as a
“cobro de lo indebido” — a kind of quasi-contract that mandates recovery of what
has been improperly paid. Quasi-contracts fall within the concept of implied
contracts that must be included in the claims required to be filed with the judicial
settlement of the deceased’s estate under Section 5, Rule 86 of the Rules of Court.
As such claim, it should have been filed in Special Proceedings No. 99-0023, not
before the RTC as a fourth-party complaint. The RTC, acting in the exercise of its
general jurisdiction, does not have the authority to adjudicate the fourth-party
complaint. As a trial court hearing an ordinary action, it cannot resolve matters
pertaining to special proceedings because the latter is subject to specific rules.

Metrobank responded to the RTC ruling by filing a petition for certiorari under Rule
65 before the CA.

CA RULING:
The CA affirmed the RTC’s ruling that Metrobank’s fourth-party complaint should
have been filed in Special Proceedings No. 99-0023. According to the CA, the relief
that Metrobank prayed for was based on a quasi-contract and was a money claim
categorized as an implied contract that should be filed under Section 5, Rule 86 of
the Rules of Court. Based on the statutory construction principle of lex specialis
derogat generali, the CA held that Section 5, Rule 86 of the Rules of Court is a
special provision that should prevail over the general provisions of Section 11, Rule
6 of the Rules of Court. The latter applies to money claims in ordinary actions while
a money claim against a person already deceased falls under the settlement of his
estate that is governed by the rules on special proceedings. If at all, rules for
ordinary actions only apply suppletorily to special proceedings.

ISSUE:
● First, are quasi-contracts included in claims that should be filed pursuant to
Rule 86, Section 5 of the Rules of Court?
● Second, if so, is Metrobank’s claim against the Estate of Jose Chua based on
a quasi-contract?

SC RULING:
● Yes. The Court held under these facts that a claim for necessary expenses
spent as previous possessor of the landis a kind of quasi-contract. Citing
Leung Ben v. O’Brien, it explained that the term “implied contracts,” as used
in our remedial law, originated from the common law where obligations
derived from quasi-contracts and from law are both considered as implied
contracts. Thus, the term quasi-contract is included in the concept “implied
contracts” as used in the Rules of Court. Accordingly, liabilities of the
deceased arising from quasi-contracts should be filed as claims in the
settlement of his estate, as provided inSection 5, Rule 86 of the Rules of
Court.
● Yes. Both the RTC and the CA described Metrobank’s claim against Chua’s
estate as one based on quasi-contract. A quasi-contract involves a juridical
relation that the law creates on the basis of certain voluntary, unilateral and
lawful acts of a person, to avoid unjust enrichment. According to the CA,
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.

In sum, on all counts in the considerations material to the issues posed, the
resolution points to the affirmation of the assailed CA decision and resolution.
Metrobank’s claim in its fourth-party complaint against Chua’s estate is based
on quasi-contract. It is also a contingent claim that depends on another
event. Both belong to the category of claims against a deceased person that
should be filed under Section 5, Rule 86 of the Rules of Court and, as such,
should have been so filed in Special Proceedings No. 99-0023.

WHEREFORE, premises considered, we hereby DENY the petition for lack of


merit. The decision of the Court of Appeals dated August 25, 2005, holding
that the Regional Trial Court of Quezon City, Branch 80, did not commit
grave abuse of discretion in denying Metropolitan Bank & Trust Company’s
motion for leave to admit fourth-party complaint is AFFIRMED. Costs against
Metropolitan Bank& Trust Company. SO ORDERED.
—-------------------------------------------------------------------------------------

SHORT VERSION

Facts: 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.

Issue: Whether or not Ayala Lumber must return the amount of said checks to
Metrobank.

Held: 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.

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