G.R. No.

200407 Landbank V Catadman

Facts:
This Court is hearing a partial appeal by way of a Petition for Review on Certiorari pursuant to
Rule 45 of the 1997 Rules of Civil Procedure questioning the March 18, 2011 Decision1 and
January 25, 2012 Resolution2 of the Court of Appeals (CA) in CA-G. The case involves three
Development Bank of the Philippines (DBP) Checks: No. 1731263 in the amount of P8,500.00
payable to GCNK Merchandising, owned by respondent Gualberto Catadman (Catadman), No.
151837 payable to National Economic Development Authority (NEDA) - Regional Office XI
and to be credited to its Land Bank Account No. 2561-0135-70. On May 26, 1999, all three
checks were cleared, but two days later, NEDA's DBP Check No. 358896 was erroneously
credited to Catadman's account, while Reyno's was inadvertently credited twice to his account.
On June 25, 2001, Land Bank discovered erroneous transactions and sent a formal demand
letter. Catadman, however, did not heed Land Bank's letter and sent another demand letter on
October 8, 2001. In February 11, 2002, Catadman acknowledged that the amount was credited
and promised to pay P2,000.00 monthly until the whole amount is returned. Gualberto Nador
Catadman was ordered to pay the private respondent Land Bank of the Philippines 40% of the
sum of P115,062.68, which corresponds to the amount of DBP Check Nos. 1731263, 1513337
and 358896 erroneously credited to his account, with interest at 6% per annum from the time of
the filing of the complaint until its full payment before the finality of judgment. The MTCC
ruled that the obligation of Catadman to reimburse Land Bank was a natural obligation and not
a civil obligation, but the RTC reversed the decision and ruled that Articles 19,11 22,12 and
145613 of the Civil Code of the Philippines are applicable to the case. Catadman must pay the
appellant one hundred thousand and two pesos and sixty eight centavos (P100,002.68) plus
legal interest to be computed from June 1, 2001 until fully paid and the costs of suit. The CA
ruled that Land Bank must bear its loss due to negligence of the bank employee and the
fiduciary nature of Land Bank's business, and adopted the 60-40 ratio.

Issues:
The Honorable Court of Appeals erred in not affirming the Regional Trial Court's decision and
not finding the petitioner liable for the full amount mistakenly credited despite concluding that
the latter was unjustly enriched at the expense of Land Bank and acted in bad faith.

Held:
The principle of unjust enrichment has two conditions: a person must have been benefited
without a real or valid basis or justification, and the benefit was derived at another person's
expense or damage. In this case, Catadman received the amount of P115,002.68 through his
bank account when the same was erroneously credited with the amount, but he spent the same
and kept his silence about it at the expense of Land Bank. The Court reprimands Land Bank for
its negligence and states that the law imposes on banks high standards in view of the fiduciary
nature of banking. Respondent Gualberto Catadman must pay petitioner Land Bank of the
Philippines P100,002.68 in damages with 12% interest per annum until full payment.

G.R. No. L-13602 Leung Ben v O'Brien

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Facts:
Leung Ben petitioned for a writ of certiorari against P. J. O'Brien and the judges of the Court of
First Instance of the city of Manila for the recovery of P15,000 alleged to have been lost in
gambling, banking and percentage games. The petitioner is requesting that the Honorable James
A. Ostrand, as the judge having cognizance of the action in said court, certify the record to this
court for review and that the order of attachment be revoked and discharged. They argue that
the statutory action to recover money lost at gaming is no such an action as contemplated in this
provision, and that the original complaint shows on its face that the remedy of attachment is not
available in aid thereof.

Issues:
Is the statutory obligation to restore money won at gaming an obligation arising from "contract,
express or implied?

Held:
The duty of the defendant to refund the money won from the plaintiff at gaming is a duty
imposed by statute and is a duty in the nature of debt. The two obligations treated in the chapter
devoted to quasi-contracts in the Civil Code are the obligation to the officious management of
the affairs of other person (gestion de negocios ajenos) and the recovery of what has been
improperly paid (cabro de lo indebido). The authors of the Code selected these two obligations
for special treatment not to deny the possibility of other quasi-contractual obligations, but
because they were the most conspicuous and had not been the subject of consideration in other
parts of the Code. Act No. 1757 has introduced modifications to the application of articles 1798,
180', and 1305 of the Civil Code, which treat of the nullity of contracts proceeding from a
vicious or illicit consideration. This means that the obligation to return money lost at play has a
decided affinity to contractual obligations, and the court had authority to issue writ of
attachment. The application for the writ of certiorari must therefore be denied and the
proceedings dismissed.

G.R. No. L-49781 People V Castañeda

Facts:
Private respondents were individually charged before the City Court of Iloilo City for
Violations of Presidential Decree No. 772 in eleven (11) separate informations, docketed as
Criminal Cases Nos. 57569 to 57579. After trial on the merits, the City Court rendered a
decision, dated June 27, 1977, acquitting the said private respondents on the ground that the
prosecution failed to prove their guilt beyond reasonable doubt. Trinidad Jason, the complainant
in the criminal cases, moved for a reconsideration of the decision for the court to order the
defendants to vacate Lot No. 1241 and surrender possession to the offended party, Trinidad
Jason, and to pay damages to the latter in whatever sum is adjudged equitable by the Honorable
Court, plus attorneys' fees of not less than P5,000.00. The Court of First Instance dismissed the
appeal and referred the case to the Court of Appeals.

Issues:

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On the basis of the trial court's findings, should the accused be ordered to surrender to the
offended party the portion of the land occupied by them.

Held:
The trial court ruled that the appeal of complainant Trinidad Jason is without merit and that the
remedy of the complainant in the case at bar is to file separate civil actions against the private
respondents for ejectment or recovery of possession.

G.R. No. 180440 HUANG v PHI and DTPCI

Facts:
This case stemmed from a Complaint for Damages filed on 28 August 1996 by petitioner Dr.
Genevieve L. Huang against respondents Philippine Hoteliers, Inc. (PHI) and Dusit Thani
Public Co., Ltd. (DTPCI). The Complaint was premised on the alleged negligence of
respondents PHI and DTPCI's staff, in the untimely putting off all the lights within the hotel's
swimming pool area, as well as the locking of the main entrance door of the area. This
negligence was compounded by respondents PHI's failure to render prompt and adequate
medical assistance. Delia Goldberg, a registered guest of Dusit Hotel, was injured when a hard
and heavy object fell on her head, causing her serious brain injury. Delia immediately got hold
of the house phone and notified the hotel telephone operator of the incident, but it took them at
least 20 minutes to get inside. According to the respondent, the hotel's swimming pool area is
open only from 7:00 a.m. to 7:00 p.m. for security reasons, housekeeping personnel to clean the
swimming pool surroundings, and people doing their exercise routine at the Slimmer's World
Gym. On 11 June 1995, Pearlie Benedicto-Lipana, the hotel staff nurse, received a call from the
hotel telephone operator informing her of a guest requiring medical assistance at the swimming
pool area. Three hotel chambermaids assisted petitioner by placing an ice pack and applying
ointment on her head, and she requested the services of the hotel physician, Dr. Violeta
Dalumpines, but Dr. Dalumpines presented a "Waiver" and demanded that it be signed by
petitioner. After checking petitioner's condition, Dr Dalumpines requested petitioner to execute
a handwritten certification and suggested an X-ray test, but petitioner refused.

Issues:
This Petition questions whether PHI and DTPCI are responsible for the safety and welfare of
the petitioner, whether the cause of action can be based on both breach of contract and tort,
whether the petitioner is entitled to damages, attorney's fees, interest, and costs of suit, and
whether the respondent insurance company is liable.

Held:
The trial court found that petitioner had a past medical history which could have been the cause
of her recurring brain injury, that Dr. Perez's findings did not prove a causal relation between
the 11 June 1995 accident and the brain damage suffered by petitioner, and that Dr. Sanchez's
testimony was hearsay. Additionally, the medical reports/evaluations/certifications issued by
doctors whom petitioner sought for examination or treatment were neither identified nor
testified to by those who issued them, meaning they cannot be given probative value. The
medical reports/evaluations/certifications of different doctors in favor of petitioner cannot be

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given probative value and their contents cannot be deemed to constitute proof of the facts stated
therein. Additionally, the medical certificates issued on their behalf and identified by another
doctor cannot be admitted as evidence unless the doctor who issued it is presented in court to
show his qualifications. In the absence of negligence on the part of respondents PHI and
DTPCI, as well as their management and staff, they cannot be made liable to pay for the
millions of damages prayed for by the petitioner. The Decision and Resolution of the Court of
Appeals in CA-G.R. CV No. 87065 dated 9 August 2007 and 5 November 2007, respectively,
are hereby affirmed.

G.R. No. L-60151 BUDLONG v APALISOK

Facts:
The petitioner filed an information before the respondent court charging private respondent
Camilo Puyon y Galagar with the crime of serious physical injuries through reckless
imprudence. During the arraignment, the accused pleaded guilty and was sentenced to 30 days
of imprisonment and to pay the costs. The petitioner filed an Ex-Parte Motion To Set Case for
Hearing for the reception of evidence to prove the civil liability of the accused. The respondent
court denied the motion and declared the case closed and terminated. The Court denied a
motion for reconsideration of the Court's Order dated 11 February 1982 on the ground that
under Sec. 4 of P.D.R. No. 968, the prosecution should have asked leave to prove the civil
liability of the defendant right before it rendered its judgment. On April 14, 1982, the Court
issued a resolution to consider the People of the Philippines as impleaded in the case and to
require the private respondent and the Solicitor General to comment thereon within ten days.

The petitioner contends that the respondent court denied the motion for reconsideration on the
grounds that the accused had already filed an application for probation. The petition is
meritorious and the February 11, 1982 order of the respondent court denying the motion is
invalid. The court convicts and sentences the defendant, but the execution of the sentence is
suspended and the defendant is released on probation. Probation involves providing
individualized community-based treatment and conditions for correction and rehabilitation. If
the defendant violates any of the conditions, the court can revoke his probation and order him to
serve the sentence. If he fulfills the terms and conditions of his probation, the case against him
is terminated and his final discharge will restore all civil rights lost or suspended and fully
discharge his liability for any fine imposed.

Held:
Under Article 113 of the Revised Penal Code, the obligation to satisfy civil liability continues
regardless of service of sentence or non-service due to amnesty, pardon, commutation of
sentence. The motion was filed on the day after the judgment of conviction and the accused was
applying for probation. Civil liability is not part of the penalty for the crime committed and is
personal to the victim. Probation may be granted if the sentence imposes a term of
imprisonment or a fine with subsidiary imprisonment in case of insolvency. The Probation Law
provides only for the suspension of the sentence imposed on the accused by virtue of his
application for probation, and there is no legal basis for the respondent court's conclusion that a

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hearing to prove the civil liability of the accused would nullify the order of suspension and
defeat the purpose of the law.

G.R 97995 PNB V CA

Facts:
B. P. Mata & Co. Inc. (Mata), a private corporation, is a manning or crewing agent for several
foreign firms, one of which is Star Kist Foods. Mata sends monthly billings to its foreign
principal Star Kist, which in turn reimburses Mata by sending a telegraphic transfer through
banks for creditSecurity Pacific National Bank (SEPAC) of Los Angeles transmitted a cable
message to the International Department of PNB to pay the amount of US$14,000 to Mata by
crediting the latter's account with the Insular Bank of Asia and America (IBAA). PNB's
International Department noticed an error and sent a service message to SEPAC Bank, which
replied with instructions that the amount should only be for US$1,400. On March 11, 1975,
PNB effected another payment through Cashier's Check No. 270271, purporting to be another
transmittal of reimbursement from Star Kist. On May 13, 1981, PNB requested Mata for refund
of the second payment after it discovered its error in effecting the second payment. The
Regional Trial Court of Manila rendered judgment dismissing the complaint ruling that the
instant case falls squarely under Article 2154 on solutio indebiti and not under Article 1456 on
constructive trust. Petitioner's demand for the return of US$14,000 was denied due to Article
1145, paragraph 2 of the Civil Code, which states that actions must be commenced within six
years. Petitioner's complaint was filed on February 4, 1982, almost seven years after making
payment.

Issues:
Invalidate the appeal court's ruling on the grounds that either Article 1456 on constructive trust
or Article 2154 of the Civil Code on..governs Mata's responsibility to return US$14,000, as an
alternative quasi-contract.

Held:
Article 1456 states that if property is acquired through mistake or fraud, the person obtaining it
is considered a trustee of an implied trust for the benefit of the person from whom the property
comes. PNB made a payment in the corrected amount of US$1,400 through Cashier's Check
No. 269522 on February 25, 1975, but fourteen days later, PNB effected another payment of
US$14,000. Private respondent argues that the case at bar is one of solutio indebiti and not a
constructive trust, as it is possible that a grantor, like PNB, may commit a mistake. The court
rules that petitioner's claim cannot prosper since it is already barred by laches, a well-settled
rule that an action to enforce an implied trust may be barred not only by prescription but also by
laches. Petitioner would attribute its mistake to the heavy volume of international transactions
handled by the Cable and Remittance Division of the International Department of PNB, but this
is not persuasive. The bank should bear the cost of its own negligence.