Case Digest (G.R. No. 210641)
Facts:
Domestic Petroleum Retailer Corporation v. Manila International Airport Authority, G.R. No. 210641, March 27, 2019, the Supreme Court Second Division, Caguioa, J., writing for the Court.Petitioner Domestic Petroleum Retailer Corporation (DPRC) leased land and a building from respondent Manila International Airport Authority (MIAA) under a Contract of Lease dated June 4, 1998. After MIAA adopted Resolution No. 98-30 (reflected in Administrative Order No. 1, Series of 1998) increasing rentals effective June 1, 1998, DPRC initially protested but paid the higher rates under protest on December 11, 1998 and continued to pay the increased rentals through December 5, 2005.
On December 1, 2004, the Court in Manila International Airport Authority v. Airspan Corporation, et al. (G.R. No. 157581) invalidated MIAA’s Resolution Nos. 98-30 and 99-11 for lack of required notice and hearing. DPRC notified MIAA on December 21, 2005 of its intention to stop paying the increased rentals and stopped doing so on January 1, 2006 while continuing to pay the contract rate. MIAA later demanded alleged arrears; DPRC replied on July 27, 2006 denying liability and demanding refund of its asserted overpayments totaling P9,593,179.87.
When MIAA ignored the demand, DPRC filed a Complaint for Collection of Sums of Money before the Regional Trial Court (RTC), Pasay City, Branch 119, on December 23, 2008. The RTC rendered judgment on August 15, 2011 in favor of DPRC, awarding the full P9,593,179.87 plus legal interest and attorney’s fees; the RTC clarified on November 17, 2011 that interest was 12% per annum from the extrajudicial demand of July 27, 2006.
MIAA appealed to the Court of Appeals (CA). The CA, in its May 31, 2013 Decision (Special Second Division), affirmed the RTC but modified liability downward, applying the six-year prescriptive period for quasi-contract (solutio indebiti) under Article 1145(2) of the Civil Code and awarding only P3,839,643.05 (payments from January 9, 2003 to December 5, 2005) plus 12% interest from July 27, 2006. DPRC’s motion f...(Pro-only)
Issues:
- Was the Court of Appeals correct in reducing MIAA’s liability to P3,839,643.05 on the ground that DPRC’s claim was a quasi-contractual claim subject to the six-year prescriptive period under Article 1145(2) (soluti...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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