Civil Law

Aniano Obaña vs Court of Appeals

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G.R. No. L-36249 – 135 SCRA 557 – Civil Law – Law on Sales – Contract of Sale – Ownership – Rescission of a Sales Contract – Unjust Enrichment 

On November 21, 1964, Chan Lin offered to buy 170 cavans of rice from Aniceto Sandoval at P37.25/sack (P6,332.50). Sandoval agreed; so from Rosales, Pangasinan, Chan Lin accompanied Sandoval’s driver to have the rice be delivered to San Fernando, La Union. Upon arriving, the sacks of rice were unloaded but when Sandoval’s driver tried to collect the payment, Chan Lin was nowhere to be found. The driver then tried to collect from Aniano Obaña, who was the owner of the store where they unloaded the rice. But Aniano refused to pay, saying that he made the payment to Chan Lin for P33/cavan and that he will not return the sacks of rice to Sandoval as they were paid already. Apparently, Aniano and Chan Lin had an earlier agreement that Chan Lin will sell him 170 cavans of rice for P33 each. Aniano said Chan Lin swindled Sandoval. Sandoval filed for replevin.

ISSUE: Who is the rightful owner of the 170 cavans of rice?

HELD: There is perfection when there is consent upon the subject matter and price, even if neither is delivered. Ownership was transferred to Chan Lin when the cavans of rice were delivered to Aniano’s store. This was agreed upon in the contract between Sandoval and Chan Lin. However, it was found that 3 days after the delivery, Chan Lin returned Aniano’s money. (At this point however, the sale between Chan Line and Aniano was voluntary rescinded by both because Chan Lin returned the purhcase price).

Aniano claimed that he then returned the cavans of rice to Sandoval. But Sandoval’s driver testified that Aniano never returned the sacks of rice. They would have withdrawn the replevin case had the sacks of rice been returned. Sandoval has all the right to recover the rice or its value and rescind the contract as he was not paid. Aniano cannot unjustly enrich himself at the expense of Sandoval.

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