Facts: Metrobank deposited the AMC checks
to Ayala Lumber and Hardware’s account; because of Chua’s control over AMC’s
operations, Metrobank assumed that the checks payable to AMC could be deposited
to Ayala Lumber and Hardware’s account.
Ayala Lumber and Hardware had no
right to demand and receive the checks that were deposited to its account;
despite Chua’s control over AMC and Ayala Lumber and Hardware, the two entities
are distinct, and checks exclusively and expressly payable to one cannot be
deposited in the account of the other.
In its fourth-party complaint,
Metrobank claims that Chua’s estate should reimburse it if it becomes liable on
the checks that it deposited to Ayala Lumber and Hardware’s account.
Issue: Whether or not Ayala Lumber must return the
amount of said checks to Metrobank.
Held: Metrobank acted in a manner akin to a mistake when it
deposited the AMC checks to Ayala Lumber and Hardware’s account because it
assumed that the checks payable to AMC could be deposited to Ayala Lumber and
Hardware’s account. This disjunct created an obligation on the part of Ayala
Lumber and Hardware, through its sole proprietor, Chua, to return the amount of
these checks to Metrobank.
This fulfills the requisites of
solutio indebiti. Metrobank’s fourth-party complaint falls under the
quasi-contracts enunciated in Article 2154 of the Civil Code. Article 2154
embodies the concept "solutio indebiti" which arises when something
is delivered through mistake to a person who has no right to demand it. It
obligates the latter to return what has been received through mistake. Solutio
indebiti, as defined in Article 2154 of the Civil Code, has two indispensable
requisites: first, that something has been unduly delivered through mistake;
and second, that something was received when there was no right to demand it.
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