Title
Osmena-Jalandoni vs. Encomienda
Case
G.R. No. 205578
Decision Date
Mar 1, 2017
A close friend lent significant sums for personal expenses, claiming loans; court ruled repayment required due to unjust enrichment, affirming oral loan validity.

Case Digest (G.R. No. 205578)
Expanded Legal Reasoning Model

Facts:

  • Procedural History
    • Carmen A. Encomienda (plaintiff) filed a sum of money claim against Georgia Osmeña-Jalandoni (defendant) before the RTC of Cebu City, Branch 57, which on January 9, 2006 dismissed the complaint.
    • On appeal, the Court of Appeals, Cebu City, in CA-G.R. CV No. 01339, reversed the RTC by Decision dated March 29, 2012 and awarded Encomienda P3,245,836.02 and US$6,638.20, plus 12% legal interest from August 14, 1997 and P100,000.00 attorney’s fees; its Resolution of December 19, 2012 denied reconsideration.
    • Osmeña-Jalandoni elevated the case to the Supreme Court, raising only whether Encomienda was entitled to reimbursement.
  • Factual Background
    • Encomienda and Jalandoni became close friends after meeting in Cebu in October 1995, Jalandoni being a real-estate broker and daughter of a prominent political family.
    • From March through October 1997, at Jalandoni’s request, Encomienda delivered cash and paid various bills and services for Jalandoni and her household through sealed envelopes and direct payments to third parties. These expenses—detailed in the CA decision—totaled P3,245,836.02 and US$6,638.20 and included publication fees, reproduction of photographs, travel and allowances, salaries of household staff and security guards, utility and communication bills, purchases of phones and cabinets, ritual and blessing fees, and petty cash.
    • On April 1, 1997 and May 26, 1997, Jalandoni also borrowed P1,000,000.00 and an additional P900,000.00, promising repayment upon her bank funds’ maturity. By July 14, 1997, she returned to Cebu without settling any obligation. Despite extrajudicial demands and a barangay conciliation during which she admitted the loans and promised repayment, Jalandoni failed to pay, prompting Encomienda to file the complaint impleading Jalandoni’s husband as a necessary party.

Issues:

  • Whether Encomienda is entitled to reimbursement of the amounts she defrayed for Jalandoni.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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