Case Digest (G.R. No. 97995)
Facts:
Philippine National Bank v. Court of Appeals and B.P. Mata & Co., Inc., G.R. No. 97995, January 21, 1993, Supreme Court Third Division, Romero, J., writing for the Court.Petitioner Philippine National Bank (PNB) maintained an international payments arrangement whereby foreign principals reimbursed local agents through telegraphic transfers. Since 1966 private respondent B. P. Mata & Co., Inc. (Mata) acted as manning agent for, among others, Star Kist Foods, Inc., and submitted monthly billings to Star Kist for crew-related advances. On February 21, 1975 Security Pacific National Bank (SEPAC), acting through its agency arrangement with PNB, transmitted a cable to PNB to credit Mata’s account with US$14,000 per Star Kist’s order; PNB received a corrected service message indicating the amount should have been US$1,400 and on February 25, 1975 caused issuance of Cashier’s Check No. 269522 for US$1,400 to Mata through the Insular Bank of Asia and America (IBAA).
Unexpectedly, fourteen days later PNB again effected payment by Cashier’s Check No. 270271 for US$14,000 (March 11, 1975), which was credited to Mata’s account. PNB only discovered the second, larger payment years later and on May 13, 1981 requested refund of the US$14,000. On February 4, 1982 PNB filed a civil action for collection and refund against Mata, asserting recovery under a constructive trust grounded on Article 1456 of the Civil Code.
The Regional Trial Court (Trial Court) of Manila dismissed PNB’s complaint, ruling the case fell under solutio indebiti (Article 2154) and not a trust, applying conventional definitions of trust and fiduciary relation. The Court of Appeals affirmed, holding that Article 2154’s quasi-contract remedy applied and that PNB’s quasi-contract cause of action had prescribed under Article 1145(2) (six-year prescription for quasi-contracts), because the suit was filed almost seven years after the March 11, 1975 payment. PNB sought relief by filing a petition for certiorari to annul the appellate decision, arguing alternatively that it could recover either by invoking a constructive trust under Article 1456 (ten-year prescription under Article 1144(2)) o...(Subscriber-Only)
Issues:
- Whether the transaction is governed by Article 1456 (constructive trust) or by Article 2154 (solutio indebiti/quasi-contract).
- If a constructive trust is available to petitioner, whether petitioner’s claim is barred by lache...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
- (Subscriber-Only)