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    The Supreme Court ruled that the quasi-contract of solutio indebiti does not apply in this case. [1] DPRC and MIAA have a binding lease contract, so payments were not made when there was no relationship between the parties. [2] DPRC's payments following the increased rental rates were not made due to mistake, as the rate increase was presumed legal at the time before being nullified by the court. [3] Therefore, the essential elements of solutio indebiti are not present, and DPRC's claim is not subject to the six-year period for claims under that quasi-contract.

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    94. DPRC vs. MIAA

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    The Supreme Court ruled that the quasi-contract of solutio indebiti does not apply in this case. [1] DPRC and MIAA have a binding lease contract, so payments were not made when there was no relationship between the parties. [2] DPRC's payments following the increased rental rates were not made due to mistake, as the rate increase was presumed legal at the time before being nullified by the court. [3] Therefore, the essential elements of solutio indebiti are not present, and DPRC's claim is not subject to the six-year period for claims under that quasi-contract.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    Download as docx, pdf, or txt
    360 views2 pages

    DPRC vs. MIAA

    Uploaded by

    Rob
    The Supreme Court ruled that the quasi-contract of solutio indebiti does not apply in this case. [1] DPRC and MIAA have a binding lease contract, so payments were not made when there was no relationship between the parties. [2] DPRC's payments following the increased rental rates were not made due to mistake, as the rate increase was presumed legal at the time before being nullified by the court. [3] Therefore, the essential elements of solutio indebiti are not present, and DPRC's claim is not subject to the six-year period for claims under that quasi-contract.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    of 2

    G.R. No.

    210641, March 27, 2019

    DOMESTIC PETROLEUM RETAILER CORPORATION, PETITIONER, v. MANILA


    INTERNATIONAL AIRPORT AUTHORITY, RESPONDENT.

    Facts: Petitioner DPRC filed a Complaint for "Collection of Sums of Money" against respondent
    MIAA. Petitioner DPRC and respondent MIAA entered into a Contract of Lease whereby the
    former leased from the latter a 1,631.12-square meter parcel of land and a 630.88-square meter
    building both located at Domestic Road, Pasay City.

    DPRC was obliged to pay monthly rentals and it faithfully complied with its obligation to pay the
    monthly rentals since the start of the lease contract.

    MIAA passed Resolution No. 98-30 which took effect on June 1, 1998 increasing the rentals
    paid by its concessionaires and lessees. MIAA issued Administrative Order reflecting the new
    schedule of fees, charges, and rates. DPRC paid respondent MIAA which was based on the
    new rates.

    On December 1, 2004, the First Division of the Court promulgated its Decision in the case
    of Manila International Airport Authority v. Airspan Corporation, et al.,. In the said case, the
    Court nullified Resolution Nos. 98-30 and 99-11 issued by respondent MIAA for non-observance
    of the notice and hearing requirements for the fixing rates required by the Administrative Code.

    Hence, DPRC demanded the refund of its excessive payments.

    The CA found that the liability of MIAA to DPRC for overpaid monthly rentals was in the nature
    of a quasi-contract of solutio indebiti. And because DPRC's claim against MIAA is purportedly in
    the nature of solutio indebiti, the CA held that "the claim of refund must be commenced within
    six (6) years from date of payment.

    The CA posited the view that the quasi-contract of solutio indebiti applies as to the instant case
    because petitioner "DPRC's payment of the increased rental to MIAA, who was found to have
    no authority to increase fees, charges and rates without the approval of the DOTC Secretary,
    due to a mistake in the interpretation and imposition of Administrative Order No. 98-30, which
    was later found to be invalid for lack of the required prior notice and public hearing, gives rise to
    the application of the principle of solutio indebiti under Articles 2154, 2155 and 2156 of the Civil
    Code in this case.

    Issue: Whether or not the cause of action of herein petitioner is based on quasi-contract of
    solution indebeti.

    Held: No. Article 2154 of the Civil Code explains the concept of the quasi-contract of solutio
    indebiti: If something is received when there is no right to demand it, and it was unduly delivered
    through mistake, the obligation to return it arises.

    The quasi-contract of solutio indebiti harks back to the ancient principle that no one shall enrich
    himself unjustly at the expense of another.17
    In order to establish the application of solutio indebiti in a given situation, 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.18 In the instant case, the
    Court finds that the essential requisites of solutio indebiti are not present.

    There exists a binding relation between petitioner DPRC and respondent MIAA.

    First and foremost, it is undisputed by all parties that respondent MIAA and petitioner DPRC are
    mutually bound to each other under a Contract of Lease. Hence, with respondent MIAA and
    petitioner DPRC having the juridical relationship of a lessor-lessee, it cannot be said that in the
    instant case, the overpayment of monthly rentals was made when there existed no binding
    juridical tie or relation between the payor, i.e., petitioner DPRC, and the person who received
    the payment, i.e., respondent MIAA. In fact, respondent MIAA itself acknowledged in its
    Comment that there was a "pre-existing contractual relation" between itself and petitioner
    DPRC.19

    Furthermore, it cannot be said that petitioner DPRC's payments in monthly rentals in


    observance with the subsequently nullified Resolution No. 98-30 were made due to mistake on
    the part of petitioner DPRC.

    Petitioner DPRC still made payment despite its objection, not due to any mistaken belief, but for
    the sole reason that prior to the Court's Decision in Manila International Airport Authority v.
    Airspan Corporation, et al., Resolution No. 98-30 was still presumed to be legal, having the
    force of law in the absence of any judicial declaration to the contrary.

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