Case Digest (G.R. No. 187240) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Carlos A. Loria v. Ludolfo P. MuAoz, Jr. (G.R. No. 187240, October 15, 2014), respondent Ludolfo P. MuAoz, Jr. filed on June 2, 2003 a complaint for sum of money and damages with application for writ of preliminary attachment before the Regional Trial Court (RTC) of Legazpi City, Branch 6 (Judge Vladimir B. Brusola presiding). MuAoz, doing business as “Ludolfo P. MuAoz, Jr. Construction,” alleged that in August 2000 petitioner Carlos A. Loria approached him in Daraga, Albay, and solicited an advance of ₱2,000,000.00 to secure a 20% subcontract on a ₱50,000,000.00 river-dredging project in Guinobatan. Loria represented that he would arrange for Sunwest Construction and Development Corporation to be the lowest bidder and that Sunwest would later subcontract P10,000,000.00 of the project to MuAoz. Pursuant thereto, MuAoz caused Allied Bank to release ₱3,000,000.00 from his joint account to one Grace delos Santos, who turned over the funds to Loria. Four days later, ₱1,800,000.00 Case Digest (G.R. No. 187240) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Pre-contractual Engagement and Advance
- Ludolfo P. Muñoz, Jr. (Muñoz) engaged in construction under “Ludolfo P. Muñoz, Jr. Construction.” In August 2000, Carlos A. Loria (Loria) approached Muñoz to advance ₱2,000,000.00 for a supposed subcontract (20% share of a ₱50,000,000.00 river-dredging project in Guinobatan). Loria represented that Sunwest Construction (Elizaldy Co.) would be the lowest bidder and would subcontract the work to Muñoz.
- On October 2, 2000, Muñoz instructed Allied Bank to release ₱3,000,000.00 from his joint account to Grace delos Santos, from whom Loria obtained the funds. Four days later, ₱1,800,000.00 was returned to Muñoz, leaving a balance of ₱1,200,000.00 with Loria. On January 10, 2001, Loria collected the remaining ₱800,000.00. After accounting for personal loans, Muñoz issued a check for ₱481,800.00, which Loria acknowledged receiving—making the total advance to Loria ₱2,000,000.00.
- Project Outcome and Civil–Criminal Proceedings
- The river-dredging project was awarded to Sunwest via public bidding. Sunwest completed the work without subcontracting to Muñoz. Muñoz demanded return of his ₱2,000,000.00; Loria refused.
- Muñoz first filed estafa charges against Loria and Elizaldy Co., which the Municipal Trial Court dismissed for lack of probable cause. He then filed a civil complaint for sum of money and damages with the RTC Branch 6 of Legazpi City.
- Trial Court and Appellate Decisions
- RTC (January 30, 2004) found that Loria received ₱2,000,000.00 without performing the subcontracted work, thus unjustly enriching himself. The RTC ordered return of ₱2,000,000.00 with 12% interest from complaint filing, ₱100,000.00 attorney’s fees, ₱25,000.00 litigation expenses, and ₱25,000.00 exemplary damages.
- CA (October 23, 2008) affirmed the RTC’s factual findings on the ₱2,000,000.00 advance (supported by a check voucher in evidence) and the application of unjust enrichment. It deleted attorney’s fees and exemplary damages. CA’s resolution denying reconsideration was issued March 12, 2009.
- Loria petitioned to the Supreme Court via Rule 45 certiorari, contesting both the factual finding of receipt and the application of unjust enrichment/in pari delicto doctrines. A joint motion to compromise was denied (Dec. 15, 2010).
Issues:
- Whether Loria initially received ₱3,000,000.00 from Grace delos Santos, as alleged by Muñoz.
- Whether Loria is liable to return ₱2,000,000.00 to Muñoz under the principle of unjust enrichment.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)