G.R. No. 199451 - Rodriguez vs. Your Own Home Development Corp.

Iris Rodriguez, the petitioner, initiated this action against Your Own Home Development Corporation (YOHDC).
The case arose out of a low‐cost housing project in Occidental Mindoro involving YOHDC and its partner, Archangel Corporation.
Tarcisius Rodriguez, Iris’s husband, was employed as the project coordinator/manager.

Tarcisius was tasked with locating a parcel of land for the project and identified a property owned by Rosa Rosillas.
According to YOHDC, an agreement was reached for the sale of the land at P1,200,000.00; however, Tarcisius misrepresented that Rosillas had asked for P4,000,000.00.
Payments were made to Rosillas in two installments and further checks were issued later which indicated higher amounts, suggesting misrepresentation and irregularities.

Two checks in the name of Rosillas.
Two checks in the name of Engineer Senen Delos Reyes, contracted to survey Rosillas' property.

Instead of delivering the checks to the intended payees, the Rodriguez spouses deposited two of Rosillas’ checks and one of Delos Reyes’ checks in one personal Bank of the Philippine Islands (BPI) account, while the remaining two were deposited in another account.
YOHDC later discovered that the endorsement signatures on the checks did not match those on file and that both sets of checks, though intended for different individuals, were deposited in the same bank account.

Upon noticing irregularities and receiving reports of padding of expenses and overpricing, YOHDC investigated and confirmed that neither Rosa Rosillas nor Senen Delos Reyes had received, endorsed, or encashed their checks.
YOHDC demanded reimbursement from Tarcisius, who failed to return the amounts. A settlement was attempted through the transfer of properties but eventually failed.
YOHDC pursued claims against the banks. Following a series of communications with Metrobank and the Bank of the Philippine Islands, the Rodriguez spouses deposited a total amount of P1,508,800.00 in one of their BPI accounts on the bank’s instructions.
The Rodriguez spouses subsequently filed a Complaint for Damages against YOHDC, BPI, Metrobank, and the intended payees (Rosillas and Delos Reyes).

The Regional Trial Court, in its decision dated August 13, 2007, dismissed the case against Rosillas, Delos Reyes, Metrobank, and BPI, but separately held YOHDC liable to reimburse the Rodriguez spouses P424,000.00 based on what was alleged to be the amount received by Delos Reyes.
The Court of Appeals, in its July 18, 2011 Decision, modified the Regional Trial Court ruling by denying the application of the principle against unjust enrichment.

The CA gave more credence to Delos Reyes’ notarized Affidavit (which denied receipt of the checks) than to his Answer and private Acknowledgement that indicated otherwise.
Notable discrepancies, such as mismatched check numbers and inconsistencies in the amounts, were highlighted.

Iris filed a Motion for Reconsideration of the CA Decision, which was eventually denied in the November 23, 2011 Resolution.
Subsequently, Iris filed the Petition for Review on Certiorari before the Supreme Court, contesting the Court of Appeals’ ruling.

Whether or not YOHDC is liable to reimburse Iris Rodriguez in the amount of P424,000.00 based on the principle of unjust enrichment.

The petitioner contends that Delos Reyes received P424,000.00 and that by reimbursing this amount, YOHDC was unjustly enriched at her expense.
Iris asserts that Delos Reyes’ later Answer and Acknowledgement constitute an abandonment of his earlier Affidavit denying any receipt of payment.

Whether the factual issues regarding the authenticity and reconciliation of the conflicting documents (i.e., Delos Reyes’ Affidavit, Answer, and private Acknowledgement) should be resolved in a petition for review on certiorari.

The petitioner’s argument raises a factual dispute about whether the payment was actually made.
YOHDC challenges the reliability of the documents presented by Iris, describing them as inconsistent and potentially resulting from misrepresentations and fraud.