NO UNJUST ENRICHMENT WHEN OBLIGATION TO SECURE MORTGAGE WAS ACTUALLY

COMPLIED WITH
Enrichment consists of every patrimonial, physical or moral advantage, so long as it is appreciable in
money. It may also take the form of avoidance of expenses and other indispensable reductions in the
patrimony of a person. It may also include the prevention of a loss or injury. (Sps. Mario & Corazon
Villalva vs. RCBC Savings Bank, G.R. NO. 165661, August 28, 2006)

NO UNJUST ENRICHMENT WHEN OBLIGATION TO SECURE MORTGAGE WAS ACTUALLY

COMPLIED WITH

Sps. Mario & Corazon Villalva vs. RCBC Savings Bank

G.R. NO. 165661; August 28, 2006
Puno, J.

FACTS:
A petition for review on certiorari under Rule 45 before the SC which seeks to reverse the decision of
the CA ordering Spouses Mario & Corazon Villalva (spouses) to pay Rizal Commercial Banking
Corporation Saving Bank (RCBC) P3,583.50 and issued a writ of replevin for the mortgaged vehicle.

Petitioner spouses issued forty-eight (48) checks to cover installment payments for a '93 Toyota Corolla
which were secured by a Deed of Chattel Mortgage. Under the Deed, the spouses were to insure the
vehicle against loss or damage by accident, theft and fire, and endorse and deliver the policies to the
mortgagor. The promissory notes and chattel mortgage are ultimately assigned and encashed by RCBC.
The evidence shows that the spouses procured the necessary insurance. They however failed to timely
deliver the same to respondent until much later. As a consequence, RCBC had the mortgaged vehicle
insured in the meantime. The insurance policy obtained by RCBC was later cancelled due to the
insurance policy secured by the Spouses. The premium paid by respondent exceeded the reimbursed
amount paid by insurer.

RCBC demanded that the spouses surrender the mortgaged vehicle within five days from notice by
reason of unpaid obligations on the promissory notes and mortgage. The petitioner spouses ignored the
demand letter and asserted that they insured the mortgaged vehicle in compliance with the Deed of
Chattel Mortgage. The MTC ruled in favor of the spouses. Such was affirmed by the RTC, but
subsequently reversed by the CA. RCBC contends that to set aside its decision would result in the unjust
enrichment of the petitioners on the ground that its payment of insurance premiums on behalf of the
petitioners unjustly enriched the latter.

ISSUE:
Is the mortgagee who obtained insurance policy but did not deliver said policy to the mortgagor as
required by the terms of a chattel mortgage unjustly enriched when the mortgagor paid for the premiums
to obtain insurance policy covering the same chattel and the same period?

HELD:
NO. He is not unjustly enriched since the spouses were able to secure the necessary insurance and
only delayed the furnishing thereof to RCBC.

Enrichment consists of every patrimonial, physical or moral advantage, so long as it is appreciable in

money. It may also take the form of avoidance of expenses and other indispensable reductions in the
patrimony of a person. It may also include the prevention of a loss or injury. In the case at bar, petitioner
spouses were not enriched when respondent obtained insurance coverage for the mortgaged vehicle as
the petitioner spouses had already obtained the required insurance coverage for the vehicle.

Hence, the mortgagee who obtained insurance policy but did not deliver said policy to the mortgagor as
required by the terms of a chattel mortgage is not unjustly enriched when the mortgagor paid for the
premiums to obtain insurance policy covering the same chattel and the same period.