Dometila Andres v Manufacturers Hanover and Trust Corp, CA GR No.

L-82670 9/15/1989 Facts of the case: Facets was a US based company that is doing business with Irenes Wearing Apparel, the latter is operated by Dometila Andres. As payment for the merchandise bought by Facets, the latter instructed FNSB to remit the amount of 10,000 USD to the PNB account of IWA. FNSB in turn instructed Mantrust to remit the money to the PNB account of IWA and just debit FNSBs account with Mantrust. The transfer was delayed due to an error (Wearing Apparel only; lacks Irenes). Acting on this error, Facets now instructs FNSB to transfer the money to PCIB instead of PNB, now FNSB instructs Mantrust to do the same. Unaware that IWA had already received the money, another remittance of 10,000 USD was transferred to IWA. FNSB discovered this had asked Mantrust to recredit the 2nd amount, to which the latter complied. Now, Mantrust asked IWA to return the 2nd amount, IWA refused to do so. Mantrust filed an action for the recovery of the amount. IWA contendeds that the money was transferred due to negligence and carelessness of the staff of the bank and that Facets had an outstanding amount of 49,000 plus USD, so there was no unjust enrichment. Issue: Whether or not IWA was unjustly enriched because of the erroneous 2nd transfer? Held: Yes. Ratio: Art. 2154. If something received when there is no right to demand it, and it was unduly delivered through mistake, the obligation to return it arises. This legal provision, which determines the quasi-contract of solution indebiti, is one of the concrete manifestations of the ancient principle that no one shall enrich himself unjustly at the expense of another. In the Roman Law Digest the maxim was formulated thus: "Jure naturae acquum est, neminem cum alterius detrimento et injuria fieri locupletiorem." And the Partidas declared: "Ninguno non deue enriquecerse tortizeramente con dano de otro." Such axiom has grown through the centuries in legislation, in the science of law and in court decisions. The lawmaker has found it one of the helpful guides in framing statutes and codes.