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

Case Summary (G.R. No. 199451)

Petitioner

Iris Rodriguez sought review of the Court of Appeals’ modification of a Regional Trial Court judgment that had ordered YOHDC to reimburse the Rodriguez spouses P424,000. Iris contends that she is entitled to reimbursement under the principle against unjust enrichment because Delos Reyes admitted receipt of P424,000 in his Answer and a private Acknowledgement, and because YOHDC recovered funds from the drawee/collecting bank.

Respondent and Other Parties

YOHDC defended against liability, contending (among other points) that the admissions relied upon by Iris were questions of fact improperly raised in a Rule 45 petition; that the notarized Affidavit of Delos Reyes denying receipt or encashment is a public document entitled to presumption of regularity; that the private Acknowledgement and related pleadings were unauthenticated and inconsistent; and that bank collection principles justified the reimbursement to YOHDC by the drawee/collecting banks.

Key Dates

Relevant chronological events include: payments to Rosillas in April–May 1993; issuance of Metrobank checks in 1993; occurrences and deposit actions culminating in 1995 (Delos Reyes’ March 14, 1995 notarized Affidavit and June 9, 1995 private Acknowledgement); the RTC decision of August 13, 2007; the Court of Appeals decision of July 18, 2011 and denial of reconsideration on November 23, 2011; the filing of the petition for review on certiorari in January 2012; and the Supreme Court disposition on review.

Applicable Law and Legal Standards

Constitutional framework: the 1987 Philippine Constitution (applicable because the Supreme Court decision date is after 1990). Procedural and evidentiary standards employed include Rule 45, Section 1 of the Rules of Court (petition for review on certiorari raises only questions of law); Rule 132, Section 20 on proof of private documents; presumption of regularity and evidentiary weight accorded to notarized (public) documents; the standard that a party seeking to rebut a notarized document must produce clear, strong, and convincing evidence; Article 22 of the Civil Code governing unjust enrichment; and bank-collection principles regarding forged indorsements and the chain of liability (as expounded in Associated Bank v. Court of Appeals).

Factual Background

YOHDC, in a joint venture with Archangel Corporation for a low-cost housing project, engaged Tarcisius Rodriguez as project coordinator/manager to secure land. Tarcisius negotiated purchase of Rosillas’ land, which YOHDC says was bought for P1,200,000 (paid in two installments). Tarcisius represented to the partners that the price was P4,000,000 and obtained additional Metrobank checks in Rosillas’ and Delos Reyes’ names. The Rodriguez spouses received four Metrobank checks, two payable to Rosillas and two to Delos Reyes.

Handling of Checks and Deposits

Instead of delivering checks to the named payees, the Rodriguez spouses deposited two of the checks (one Rosillas check and one Delos Reyes check) totaling P754,400 into a BPI account they held, and deposited the remaining two checks into another joint BPI account. Iris was employed as a bank teller at BPI during this period. Endorsements on the presented checks differed from signatures on file, and checks payable to two different payees were deposited into the same BPI accounts.

Discovery and Bank Actions

YOHDC discovered irregularities after reports of project anomalies and investigation of the checks. YOHDC pursued claims against Metrobank and BPI for recovery. Metrobank advised YOHDC to direct claims to BPI; BPI in turn urged submission via Metrobank. BPI demanded the Rodriguez spouses deposit P1,508,800 to respond to YOHDC’s complaint; the spouses deposited that amount but sought a hold, which BPI denied. BPI issued a special clearing receipt to Metrobank, and Metrobank credited YOHDC. The Rodriguez spouses then filed a Complaint for Damages against YOHDC, BPI, Metrobank, Rosillas, and Delos Reyes.

Procedural History — Trial Court Ruling

At the RTC level, the case against Rosillas, Delos Reyes, Metrobank, and BPI was dismissed. The RTC found, based on Delos Reyes’ Answer (which the RTC interpreted as admitting receipt), that Delos Reyes had received P424,000 and ordered YOHDC to reimburse the Rodriguez spouses P424,000 under the principle against unjust enrichment, plus attorney’s fees.

Court of Appeals Ruling

The Court of Appeals modified the RTC decision, ruling that unjust enrichment did not apply and that the private Acknowledgement relied upon by the Rodriguez spouses was a private document whose execution and authenticity were not proven as required by the rules of evidence. The CA accorded greater weight to Delos Reyes’ duly notarized March 14, 1995 Affidavit in which he denied receiving, endorsing, encashing, or depositing the checks. The CA noted inconsistencies in alleged check numbers and circumstances and concluded YOHDC was not liable for P424,000 or attorney’s fees.

Issue Presented to the Supreme Court

The sole issue presented to the Supreme Court was whether YOHDC is liable to Iris Rodriguez for P424,000 based on the principle of unjust enrichment, given the factual record and the evidentiary disputes concerning whether Delos Reyes received P424,000 from the proceeds of the subject checks.

Standard of Review — Questions of Law Versus Fact

The Supreme Court emphasized Rule 45’s limitation: a petition for review on certiorari under Rule 45 raises only questions of law, not questions of fact. The central dispute (whether Delos Reyes had been paid P424,000 from the checks) is a question of fact requiring review of evidence and credibility determinations, which the Court will not undertake in a Rule 45 petition. Thus, much of Iris’ contention amounted to impermissible recasting of factual issues as legal ones.

Evidentiary Analysis — Notarized Affidavit Versus Private Acknowledgement

The Supreme Court analyzed the conflicting documentary evidence: Delos Reyes’ notarized March 14, 1995 Affidavit (a public document) denying any receipt or encashment of the checks versus a June 9, 1995 private Acknowledgement (Annex D-1) and an apparent admission in Delos Reyes’ Answer that he received P424,000. The Court reiterated the well-settled rule that notarized documents enjoy a presumption of regularity, genuineness, and due execution and are admissible without further proof; to overcome this presumption, the opposing party must present clear, strong, and convincing evidence of falsity. By contrast, private documents must be authenticated under Rule 132, Section 20, and ordinarily require the author’s testimony or other best available proof. The Court found that Iris failed to authenticate or prove the private Acknowledgement’s due execution and genuineness and that Delos Reyes nev

Case Syllabus (G.R. No. 199451)

Case Title, Citation, and Procedural Posture

Supreme Court, Third Division, G.R. No. 199451, August 15, 2018; decision penned by Justice Leonen with concurrence by Leonardo-De Castro (Chairperson), Bersamin, A. Reyes, Jr., and Gesmundo, JJ.
Petition for Review on Certiorari from the Court of Appeals Decision dated July 18, 2011 and Resolution dated November 23, 2011 in CA-G.R. CV No. 90297.
The Court of Appeals had modified the Regional Trial Court (RTC) Decision of August 13, 2007 which ordered Your Own Home Development Corporation (YOHDC) to pay Iris Rodriguez P424,000.00; the Court of Appeals found YOHDC not liable and denied reimbursement and attorney’s fees.
Petitioner (Iris Rodriguez) sought Supreme Court review, urging affirmation of the RTC decision that had awarded P424,000.00 and attorney’s fees; respondent is YOHDC. The Supreme Court denied the petition and affirmed the Court of Appeals decision and resolution.

Facts — Project, Actors, and Check Transactions

Case arose from a low-cost housing joint project in Occidental Mindoro between YOHDC and Archangel Corporation; Tarcisius Rodriguez (Tarcisius), husband of petitioner Iris Rodriguez, was hired as project coordinator/manager.
Tarcisius located land owned by Rosa Rosillas (Rosillas) and negotiated its sale; Rosillas was paid P1,200,000.00 in two installments on April 8, 1993 and May 14, 1993.
According to YOHDC, Rosillas agreed to sell for P1,200,000.00; Tarcisius purportedly misrepresented to the partner corporations that Rosillas had asked for P4,000,000.00.
Nonetheless, Tarcisius requested two additional checks in Rosillas’ name, each for P500,000.00; YOHDC issued Metrobank Check Nos. 1181043810 and 1181043843 (the Rosillas’ Checks).
Tarcisius also requested two checks to pay the surveyor, Engineer Senen Delos Reyes (Delos Reyes), in the amount of P254,400.00 each; YOHDC issued Metrobank Check Nos. 1181043813 and 1181043841 (the Delos Reyes’ Checks).
Tarcisius received all four Metrobank checks. Instead of delivering them to Rosillas and Delos Reyes, Tarcisius and Iris (the Rodriguez Spouses) deposited two checks—a Rosillas’ Check and one Delos Reyes’ Check—totaling P754,400.00 into their personal BPI Account No. 3293-0730-06, and deposited the other two checks into their other personal BPI Account No. 0065-0506-25.
YOHDC later discovered irregularities (reports of padded expenses and overpricing). Investigation revealed that endorsement signatures on the checks were different from signatures on file; the checks for two different payees (Rosillas of Bulacan; Delos Reyes of Mindoro) were deposited into the same BPI accounts.
Iris was a BPI bank teller at the relevant time.
YOHDC contacted Rosillas and Delos Reyes; both confirmed they never received, endorsed, encashed, or deposited any of the four checks.
YOHDC demanded reimbursement from Tarcisius; he proposed settling by transferring properties but no settlement occurred. YOHDC then pursued claims against the banks.

Banking Responses, Reimbursements, and Deposit Details

YOHDC first sought reimbursement from Metrobank; Metrobank advised YOHDC to direct its claim to BPI. BPI advised YOHDC to route documents through Metrobank.
Pursuant to Metrobank’s instructions, YOHDC submitted the Rosillas’ and Delos Reyes’ Checks and affidavits to Metrobank, which forwarded them to BPI.
BPI advised the Rodriguez Spouses to deposit the amount of P1,508,800.00 into their BPI account to enable BPI to respond to YOHDC’s complaint; the Rodriguez Spouses complied and deposited P1,508,800.00 in BPI Account No. 3293-0994-39, but requested BPI to suspend action and not to deduct the amount pending clarification.
BPI denied the request and sent Metrobank Special Clearing Receipt No. 065273 to reimburse the amounts of the four checks. The documents state that Metrobank credited the amount to YOHDC. (The records in the source display the amounts P1,508,800.00 and a later reference to amounts totaling P1,508,000.00 as reimbursed; both figures appear in the record excerpts.)

Pleadings, Admissions, and Documentary Claims by Rodriguez Spouses

The Rodriguez Spouses filed a Complaint for Damages against BPI, Metrobank, YOHDC, Rosillas, Delos Reyes, and others.
They claimed Rosillas’ Checks were received by Rosillas’ agent, Godofredo Syquioco (Syquioco).
They asserted that Delos Reyes received P424,000.00 from proceeds of Metrobank Check Nos. 181043813 and 181043841 and claimed that all four checks were encashed through BPI with Iris’ assistance.
Annex “D-1” to the complaint included an Acknowledgement signed by Senen M. Delos Reyes dated June 9, 1995, stating that he had received P424,000.00 as partial payment for services and referencing Metrobank cheques 181043813 and 181043841.

Regional Trial Court Ruling (August 13, 2007)

RTC dismissed the case against Rosillas, Delos Reyes, Metrobank, and BPI.
RTC noted Delos Reyes’ Answer dated July 9, 1995 wherein he admitted receipt of portions of the proceeds of his checks totaling P424,000.00.
Based on the principle against unjust enrichment, the RTC ordered YOHDC to reimburse the Rodriguez Spouses P424,000.00 (the amount that Delos Reyes had received), and ordered YOHDC to pay P50,000.00 as attorney’s fees; costs were charged against YOHDC.
RTC’s dispositive portion read in full: “The case as against defendants ROSA ROSILLAS, SENEN DELOS REYES, METROBANK and BPI are hereby ordered DISMISSED; Defendant YOUR OWN HOME DEVELOPMENT CORPORATION is hereby ordered to pay plaintiffs the amount of Php 424,000.00 representing the amount already paid by plaintiffs to defendant Senen delos Reyes; and Defendant YOUR OWN HOME DEVELOPMENT CORPORATION to pay plaintiffs the amount of Php 50,000.00 as attorney's fees. Costs against the defendant YOUR OWN HOME DEVELOPMENT CORPORATION. SO ORDERED.”

Court of Appeals Ruling (July 18, 2011) and Reasoning

On appeal, the Court of Appeals modified the RTC decision and found that the principle against unjust enrichment did not apply; it held YOHDC not liable for the P424,000.00 and not liable for attorney’s fees.
The Court of Appeals declined to lend credence to Delos Reyes’ Acknowledgement (a private document) because its execution and authenticity were not proven as required by the rules of evidence.
The Court of Appeals credited evidence presented by YOHDC: payment receipts to Delos Reyes and Delos Reyes’ duly notarized Affidavit dated March 14, 1995 (Delos Reyes’ Affidavit) which stated he never received, encashed, or deposited the checks and that indorsements were not his signatures.
The Court of Appeals observed that, even if Delos Reyes had been paid P424,000.00, that amount could not have come from Delos Reyes’ checks because the two Delos Reyes’ Checks totalled P508,800.00; the Court was unpersuaded by Tarcisius’ explanation that the difference represented extra-legal expenses for title issuance.
The Court of Appeals also noted discrepancies in check numbers: Rodrigue