Professional Documents
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DPRC vs. MIAA
DPRC vs. MIAA
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.
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
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.