Locsin, II v Mekeni Food Corporation, G.R. No. 192105; December 9, 2013; Del Castillo, J.

FACTS:

Petitioner Antonio Locsin II was hired by respondent Mekeni Food Corporation as Regional Sales Manager in South Luzon. Mekeni furnished petitioner a vehicle to effectively cover his appointed sales territory. Petitioner was able to pay 50% of the car value through salary deductions and applied for employee’s car plan. When petitioner resigned, he made an offer to purchase the said car by paying the balance however they could not agree on the terms of the proposed purchase so he returned the car. On the letter he addressed to Mekeni, he indicated the demand on unpaid salaries, benefits, commissions and the purchase of the car but Mekeni answered that the car plan is only for employees who had been there for five years and added that if petitioner wishes to have the car he should pay the balance. Petitioner filed a complaint for unpaid salaries and recovery of monthly salary deductions for the supposed car plan.

ISSUE:

Whether or not petitioner may reimburse the salary deductions for the car plan by virtue of quasi-contract created between the parties.

RULING:

Yes.

In light of the foregoing, it is unfair to deny petitioner a refund of all his contributions to the car plan. Under Article 22 of the Civil Code, "[e]very person who through an act of performance by another, or any other means, acquires or comes into possession of something at the expense of the latter without just or legal ground, shall return the same to him." Article 2142 of the same Code likewise clarifies that there are certain lawful, voluntary and unilateral acts which give rise to the juridical relation of quasi-contract, to the end that no one shall be unjustly enriched or benefited at the expense of another. In the absence of specific terms and conditions governing the car plan arrangement between the petitioner and Mekeni, a quasi-contractual relation was created between them. Consequently, Mekeni may not enrich itself by charging petitioner for the use of its vehicle which is otherwise absolutely necessary to the full and effective promotion of its business. It may not, under the claim that petitioner’s payments constitute rents for the use of the company vehicle, refuse to refund what petitioner had paid, for the reasons that the car plan did not carry such a condition; the subject vehicle is an old car that is substantially, if not fully, depreciated; the car plan arrangement benefited Mekeni for the most part; and any personal benefit obtained by petitioner from using the vehicle was merely incidental.