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Locsin II v. Mekeni Food Corporation (December 9, 2013)

opic! "#asi Contract

Doctrine! Article 2142 of the Civil Code claries that there are certain lawful, voluntary andunilateral acts which give rise to the juridical relation of quasi-contract, to the end that noone shall be unjustly enriched or beneted at the exense of another! "n the absence of

secic ter#s and conditions governing the car lan arrange#ent between the etitionerand $e%eni, a quasi-contractual relation was created between the#!

Facts! &esondent $e%eni is the e#loyer of etitioner 'ocsin! (hen the latter was hired hewas o)ered a car lan, under which * of the cost of the vehicle is to be aid by theco#any and the other * to be deducted fro# etitioner+s salary! etitioner began wor%ingon $arch 1, 2..4, the car furnished to hi# is a used /onda Civic valued at 20.,...!etitioner aid for his . share through salary deductions of ,... each #onth!

3ubsequently, etitioner resigned e)ective ebruary 2, 2..5! 6y then, a total of 112,..had been deducted fro# his #onthly salary and alied as art of the e#loyee+s share inthe car lan! "n his resignation letter, etitioner #ade an o)er to urchase his servicevehicle by aying the outstanding balance thereon! /owever, the arties could not agree onthe ter#s of the roosed urchase! etitioner thus returned the vehicle to $e%eni on $ay 2,

2..5!

etitioner #ade ersonal and written follow-us but to no avail! $e%eni even relied that theco#any car lan benet alied only to e#loyees who have been with the co#any forve years! 7n $ay 8, 2.., etitioner led against $e%eni a co#laint for recovery of#onetary clai#s and recovery of #onthly salary deductions which were ear#ar%ed for hiscost-sharing in the car lan with the 9'&C!

Labor $rbiter!:udg#ent is rendered directing $e%eni to turn-over to etitioner thevehicle uon his ay#ent of the su# of 1..,48!04!

%n appea&' LC! 'A reversed and set aside and ordering $e%eni to ay etitioner#onetary clai#s and &;"$6. sharing a#ounting to 112,..! "t ruledthat etitioner+s a#orti?ation ay#ents on his service vehicle should be rei#bursed@ if not,

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ro# the evidence on record, it is seen that the $e%eni car lan o)ered to etitioner wassubject to no other ter# or condition than that $e%eni shall cover one-half of its value, andetitioner shall in turn ay the other half through deductions fro# his #onthly salary! $e%enihas not shown, by docu#entary evidence or otherwise, that there are other ter#s andconditions governing its car lan agree#ent with etitioner! =here is no evidence to suggestthat if etitioner failed to co#letely cover one-half of the cost of the vehicle, then all the

deductions fro# his salary going to the cost of the vehicle will be treated as rentals for hisuse thereof while wor%ing with $e%eni, and shall not be refunded! "ndeed, there is no suchstiulation or arrange#ent between the#! =hus, the CA+s reliance on ;lisco =ool is withoutbasis, and its conclusions arrived at in the questioned decision are #anifestly #ista%en! "twas a atent error for the aellate court to assu#e that, even in the absence of exressstiulation, etitioner+s ay#ents on the car lan #ay be considered as rentals which neednot be returned!

"ndeed, the Court cannot allow that ay#ents #ade on the car lan should be forfeited by$e%eni and treated si#ly as rentals for etitioner+s use of the co#any service vehicle! 9or#ay they be retained by it as urorted loan ay#ents, as it would have this Court believe!"n the rst lace, there is recisely no stiulation to such e)ect in their agree#ent!3econdly, it #ay not be said that the car lan arrange#ent between the arties was abenet that the etitioner enjoyed@ on the contrary, it was an absolute necessity in $e%eni+s

business oerations, which beneted it to the fullest extent!

"n light of the foregoing, it is unfair to deny etitioner a refund of all his contributions to thecar lan!