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G.R. No. L-36249: ANIANO OBAÑA vs. THE COURT OF APPEALS AND ANICETO SANDOVAL 1985
March 29, 135 scra 557 Contract of Sale – Ownership – Rescissible Contract – Unjust
Enrichment On November 21, 1964, Chan Lin offered to buy 170 cavans of rice from
Sandoval at P37.25/sack (P6332.50). 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, who was the storeowner 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: 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. Aniano claimed that he then returned
the cavans of rice to Sandoval. But Sandoval’s driver said 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 They would have withdrawn the replevin case had the sacks of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 and rescind the
contract as he was not paid. Aniano cannot unjustly enrich himself at the expense
of Sandoval.