G.R. No. 127141 - Spouses Lantin vs. Court of Appeals

Petitioners: Spouses Emmanuel Lantin and Melanie Lantin, former lessees of a residential house owned by Ms. Esperanza C. Reyes.
Respondents: Spouses Roland B. Beltran and Ma. Victoria Reyes-Beltran, subsequent lessees of the same house.

In March 1994, the petitioners informed Ms. Reyes that they were terminating their lease.
They vacated the premises on March 19, 1994 but retained the key to remove an installed intercom unit, finally turning it over on March 30, 1994.
On March 30, 1994, Ms. Reyes returned a check amounting to ₱8,000.00 (the one-month deposit) and later issued another check for ₱4,514.50 after deducting specific charges, as detailed in a cash voucher prepared by Ms. Reyes:

Shortly after, Ms. Reyes leased the house to the respondents, who moved in on April 23, 1994.
The respondents soon discovered outstanding utility bills, including:

Concerned about potential service interruptions, the respondents paid these bills on behalf of the petitioners.
Consequently, the respondents demanded reimbursement of ₱4,733.04 from the petitioners.

After unsuccessful barangay conciliation, the respondents filed a complaint before the Metropolitan Trial Court (MeTC) of Parañaque City, Branch 77.
The MeTC ruled in favor of the petitioners, finding that the electric bill and MPHA dues had been settled through the deductions from the deposit and dismissed the telephone bill claim.
The Regional Trial Court (RTC) of Parañaque City, Branch 259, affirmed the MeTC decision in toto on December 21, 1995.
The Court of Appeals (CA) later reversed and set aside the RTC’s decision, ruling that the petitioners were liable to reimburse the respondents for the MPHA water consumption and dues (initially set at ₱1,587.90).

The petitioners contended that they had already paid for the water consumption and MPHA dues through deductions from their deposit, as evidenced by the cash voucher issued by Ms. Reyes.
They argued that the respondents’ receipt, issued in Ms. Reyes' name, did not establish that they had actually borne the payment.
Additionally, they maintained that no privity of contract existed between the petitioners and the respondents regarding such payment.

The respondents produced documentary evidence, including a receipt from the MPHA, which showed that payment for the water consumption and association dues was made via RCBC Check No. 063635 by petitioner Roland Beltran.
They argued that the payment relieved the petitioners from the obligation to settle these utility accounts.
The CA found that the cash voucher was insufficient proof that the petitioners had discharged their obligations, particularly concerning the water and MPHA dues.

The CA, while concurring with the lower courts that there was no entitlement for reimbursement for the electric and telephone bills, ruled that the petitioners must reimburse the respondents for the water consumption and MPHA dues.
However, upon reexamination, the reimbursable amount was reduced from ₱1,587.90 to ₱1,062.90 after excluding an amount pertaining to MPHA dues for April 1994.
The case presents the issue of whether the CA correctly ordered such reimbursement and under what evidentiary standards the deductions made from the deposit are to be considered valid.

Whether the Court of Appeals correctly ordered the petitioners to reimburse the respondents for the payment made on behalf of the petitioners for water consumption and MPHA dues for the month of March 1994.

Whether the cash voucher provided by the petitioners is sufficient to prove that the water consumption and association dues had already been paid via deductions from the deposit.
Whether the respondents established, by independent evidence, that they actually settled the MPHA bill which was not entirely covered by the cash voucher.
Whether the absence of privity of contract between petitioners and respondents precludes the latter’s claim for reimbursement.
The proper accounting and period applicability (distinguishing between March and April 1994) of the utility bills.