DOMESTIC PETROLEUM RETAILER v.

MIAA
G.R. No. 210641, March 27, 2019
SECOND DIVISION
(CAGUIOA, J.)

FACTS:
DPRC and MIAA entered into a Contract of Lease. MIAA passed a
Resolution increasing the rentals paid by its concessionaires and lessees.
DPRC initially refused to pay the increased rentals which was decreed
without prior notice and hearing. However, it also signified its intention
to comply in good faith with the terms and conditions of the lease
contract by paying the amount charged.

On December 1, 2004, the Court promulgated a Decision in the case

of Manila International Airport Authority v. Airspan Corporation, et al.
Nullifying the Resolutions issued by respondent MIAA.

ISSUE:
Whether the liability of MIAA to DPRC for overpaid rentals was in the
nature of a quasi-contract of solutio indebiti and that the claim for refund
already prescribed.

HELD:
No. For solution indebiti to apply, two conditions must concur: (1) a
payment is made when there exists no binding relation between the
payor who has no duty to pay, and the person who received the
payment, and (2) the payment is made through mistake, and not
through liberality or some other cause. In the instant case, the Court
finds that the essential requisites of solutio indebiti are not present.

There exists a binding relation between DPRC and MIAA. It is undisputed

by all parties that respondent MIAA and petitioner DPRC are mutually
bound to each other under a Contract of Lease.

Also, there was no payment by mistake. DPRC deliberately made the

payments in accordance with MIAA's Resolution, albeit under protest.
Therefore, petitioner DPRC's cause of action is not based on the quasi-
contract of solutio indebiti.

DPRC’s claim against MIAA has not prescribed. Regardless of whether

the prescriptive period to be applied is the one pertaining to actions
arising from quasi-contracts, i.e., six years, or from contracts, i.e., 10
years, considering that the prescriptive period started to run only on
December 1, 2004, petitioner DPRC's claim for a complete refund of all
the overpaid rentals has not prescribed.