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    16 Andres Vs Manufacturers Hanover

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    Myla Rodrigo
    Private respondent instructed PCIB to pay $10,000 to petitioner for a purchase, unaware that petitioner had already received the initial $10,000 payment. This resulted in petitioner receiving a duplicate payment of $10,000. The Supreme Court ruled that private respondent has the right to recover the second $10,000 payment, as the requirements of Article 2154 of the Civil Code were met: there was no obligation to make the second payment, and it was made due to a mistake of fact regarding the initial payment. While petitioner claimed it was unjustly enriched, the duplicate reference invoice numbers showed the second payment was simply a mistake.

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    16 Andres Vs Manufacturers Hanover

    Uploaded by

    Myla Rodrigo
    163 views1 page
    Private respondent instructed PCIB to pay $10,000 to petitioner for a purchase, unaware that petitioner had already received the initial $10,000 payment. This resulted in petitioner receiving a duplicate payment of $10,000. The Supreme Court ruled that private respondent has the right to recover the second $10,000 payment, as the requirements of Article 2154 of the Civil Code were met: there was no obligation to make the second payment, and it was made due to a mistake of fact regarding the initial payment. While petitioner claimed it was unjustly enriched, the duplicate reference invoice numbers showed the second payment was simply a mistake.

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    Andres vs Manufacturers HanoverObligations & Contracts

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    16 Andres vs Manufacturers Hanover

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    Private respondent instructed PCIB to pay $10,000 to petitioner for a purchase, unaware that petitioner had already received the initial $10,000 payment. This resulted in petitioner receiving a duplicate payment of $10,000. The Supreme Court ruled that private respondent has the right to recover the second $10,000 payment, as the requirements of Article 2154 of the Civil Code were met: there was no obligation to make the second payment, and it was made due to a mistake of fact regarding the initial payment. While petitioner claimed it was unjustly enriched, the duplicate reference invoice numbers showed the second payment was simply a mistake.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    163 views1 page

    16 Andres Vs Manufacturers Hanover

    Uploaded by

    Myla Rodrigo
    Private respondent instructed PCIB to pay $10,000 to petitioner for a purchase, unaware that petitioner had already received the initial $10,000 payment. This resulted in petitioner receiving a duplicate payment of $10,000. The Supreme Court ruled that private respondent has the right to recover the second $10,000 payment, as the requirements of Article 2154 of the Civil Code were met: there was no obligation to make the second payment, and it was made due to a mistake of fact regarding the initial payment. While petitioner claimed it was unjustly enriched, the duplicate reference invoice numbers showed the second payment was simply a mistake.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 1

    16 ANDRES VS MANUFACTURERS HANOVER & TRUST CORP

    G.R. NO. 82670 SEPTEMBER 15, 1989

    FACTS:
    Andres, using the business name Irenes Wearing Apparel was engaged in the
    manufacture of ladies garments, childrens wear, mens apparel and linens for local
    and foreign buyers. Among its foreign buyers was Facts of the United States.
    Sometime in August 1980, Facts instructed the First National State Bank (FNSB) of
    New Jersey to transfer $10,000 to Irenes Wearing Apparel via Philippine National
    Bank (PNB) Sta. Cruz, Manila branch. FNSB instructed Manufacturers Hanover and
    Trust Corporation (Mantrust) to effect the transfer by charging the amount to the
    account of FNSB with private respondent.
    After Mantrust effected the transfer, the payment was not effected immediately
    because the payee designated in the telex was only Wearing Apparel. Private
    respondent sent PNB another telex stating that the payment was to be made to
    Irenes Wearing Apparel.
    On August 28, 1980, petitioner received the remittance of $10,000.
    After learning about the delay, Facets informed FNSB about the situation. Facts,
    unaware that petitioner had already received the remittance, informed private
    respondent and amended its instruction y asking it to effect the payment to
    Philippine Commercial and Industrial Bank (PCIB) instead of PNB.
    Private respondent, also unaware that petitioner had already received the
    remittance, instructed PCIB to pay $10,000 to petitioner. Hence, petitioner received
    another $10,000 which was charged again to the account of Facets with FNSB.
    FNSB discovered that private respondent had made a duplication of remittance.
    Private respondent asked petitioner to return the second remittance of $10,000 but
    the latter refused to do so contending that the doctrine of solution indebiti does not
    apply because there was negligence on the part of the respondents and that they
    were not unjustly enriched since Facets still has a balance of $49,324.
    ISSUE: Whether or not the private respondent has the right to recover the second
    $10,000 remittance it had delivered to petitioner
    HELD:
    Yes. Art 2154 of the New Civil Code is applicable. For this article to apply, the
    following requisites must concur: 1) that he who paid was not under obligation to do
    so; and 2) that payment was made by reason of an essential mistake of fact.
    There was a mistake, not negligence, in the second remittance. It was evident by
    the fact that both remittances have the same reference invoice number.

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