Case Digest (G.R. No. 199451)
Facts:
Iris Rodriguez v. Your Own Home Development Corporation (YOHDC), G.R. No. 199451, August 15, 2018, the Supreme Court Third Division, Leonen, J., writing for the Court.Petitioner Iris Rodriguez (Iris) and her late husband Tarcisius Rodriguez were involved in a low‑cost housing joint venture between YOHDC and Archangel Corporation in Occidental Mindoro. Tarcisius, engaged as project coordinator/manager, located land owned by Rosa Rosillas and negotiated its purchase. YOHDC issued several Metrobank checks purportedly to pay Rosillas (P1,200,000) and to pay geodetic engineer Senen Delos Reyes (two checks of P254,400 each). Tarcisius received the checks and, together with Iris (both of whom held BPI accounts), deposited four checks in two personal BPI accounts instead of delivering them to the intended payees.
YOHDC discovered irregularities—signatures on indorsements differed from those on file and checks payable to different persons were deposited to the same BPI accounts. BPI alerted the Rodriguez spouses to a demand for P1,508,800; the spouses deposited that amount in a third BPI account but asked BPI to suspend action; BPI nevertheless forwarded reimbursement to Metrobank and Metrobank credited YOHDC. The Rodriguez spouses then filed a complaint for damages against YOHDC, BPI, Metrobank, Rosillas, Delos Reyes and others, alleging that the checks had been encashed with Iris’s assistance and that Delos Reyes received P424,000 of the proceeds.
At the Regional Trial Court (RTC), Branch 259, Paranaque (Judge Zosimo V. Escano), the case against Rosillas, Delos Reyes, Metrobank and BPI was dismissed, but the RTC found that Delos Reyes admitted receiving P424,000 in his July 9, 1995 Answer and ordered YOHDC to reimburse the Rodriguez spouses P424,000 plus attorney’s fees (August 13, 2007 Decision).
On appeal, the Court of Appeals (CA) (Former Sixth Division) modified the RTC decision (July 18, 2011): it declined to give probative value to Delos Reyes’s alleged Acknowledgement because it was a private document not properly authenticated, and instead credited Delos Reyes’s notarized March 14, 1995 Affidavit denying receipt, concluding YOHDC was not liable for P424,000 (and denied attorney’s fees). Iris’s motion for reconsideration before the CA was denied (November 23, 2011 Resolution).
Iris filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court (filed January 25, 2012) asking this Court to reinstate the RTC award. Her principal contention was that Delos Reyes’s Answer constituted an admission that he received P424,000 and that any later affidavit was abandoned. YOHDC countered that Iris raised questions of fact unsuitable for Rule 45 ...(Pro-only)
Issues:
- Does the Petition for Review on Certiorari raise a question of law such that this Court may review the factual findings of the lower courts under Rule 45?
- Is YOHDC liable to Iris Rodriguez for P424,000.00 under the principle of unjust enrichment (Art. 22, Civil Code) based on Delos Reyes’s alleged receipt an...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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