189.

Flores

PCIB v CA

Facts:

Atlas Consolidating Mining and Development Corporation (Atlas), had purchased

with an official Deed of Sale of assorted mining machinery and equipment jointly owned
by PCIB and MBC and mortgaged by PIM. The purchase had the current status of 12
million pesos down payment and a balance of 18 million pesos to be paid within six
monthly instalments. The stipulation of the contract of sale had included that the total
purchase price to exclude items that would belong to the Bureau of Mines; full and
sufficient titles of the properties; freeing the properties from all liens and encumbrances;
freeing Atlas from all claims and incidental actions of NAMAWU; and the seller is
required to convey the title for the peaceful deliveries to Atlas.
The final price as provided by PCIB and MBC was P29,630,000 and the following
instalments must be according to the provisions of PCIB receiving 63.1579% and MBC
receiving 36.8421%. Atlas had than paid P4,298,307.77 for a writ of garnishment to
satisfy final judgement to NAMAWU instead of PIM. PCIB and MBC had than filed a
petition for certiorari on the ground that Atlas had the right to receive the said properties
free from any lien and encumbrance. As of the remaining balances of Atlas, a total of
P13,696,692.22 was paid to PCIB and MBC. Atlas had shed light to the previous
payments and had asserted that the petitioner should accredit the payment of
P4,298,307.77 along with the sheriff’s fee of P5,000. Atlas over all claimed that with
these payments, P30,000 was paid but with an additional over payment of P370,000
and that PCIB should reimburse P233,684.23. PCIB refused so Atlas sued. PCIB did
not with Atlas potential reason of accreditation due to NAMAWU receiving more than
what it was entitled to by reason of final judgement.
Issue: Whether or not Atlas had overpaid or under paid PCIB.

Ruling:

In the case at bar, the Court of Appeals had ruled that Atlas had underpaid PCIB.
The parties involved in these affairs was PCIB as a debtor from purchasing the legally
garnished properties and Atlas is to be known as the third person that paid the
obligation of the debtor without the latter’s knowledge and consent. Since Atlas had paid
NAMAWU without the knowledge and consent of PCIB, Atlas can only be reimbursed
the amount that benefited the latter. A general principle that is inapplicable in this matter
is that a third person who paid someone else’s debt is entitled to recover the full amount
that was rendered. However an exception to that rule that has been applied to this case
is that the law limits the recovery of the amount that the debtor has been benefited, if
the debtor had no knowledge of, or expressed opposition of payment [Article 1236 of
the Civil Code]. Therefore, Atlas should file an action of the receiver of the payment
which was NAMAWU for paying an amount not due. The court had overall ruled that
Atlas was still liable to payP146,058.96 to PCIB.