Villalva vs rbc

Facts:

1. The evidence shows that the petitioner spouses faithfully complied with the obligation to
insure the mortgaged vehicle from 1993 until 1996. For the period of August 14, 1996 to
August 14, 1997, petitioner spouses procured the necessary insurance but did not deliver
the same to the respondent until January 17, 1997.
2. Consequently, respondent had the mortgaged vehicle insured and paid a
P14,523.36 insurance premium which was cancelled due to the insurance policy was
obtained by petitioners.
3. Respondent was reimbursed by the insurance company amounting to P10,939.86. The
insurance premium paid by the respondent exceeded the reimbursable amount
byP3,583.50
4. In order to retrieve the mortgaged vehicle, filed a complaint for Recovery of Possession
with Replevin with the Metropolitan Trial Court of Pasay City and cause the enforcement of
a writ of replevin and recovered possession of the mortgaged vehicle.
5. Petitioner spouses filed their Answer with Compulsory Counterclaim for moral damages,
exemplary damages and attorney’s fees asserting that they insured the mortgaged vehicle in
compliance with the Deed of Chattel Mortgage
6. Metropolitan Trial Court rendered a decision in favor of petitioners and
ordered respondent to pay petitioner spouses the amount covering moral damages,
exemplary damages, attorney’s fees, and the costs and expenses of litigation
7. The respondent appealed but Regional Trial Court affirmed the decision of the lower court.
8. Undaunted, the respondent filed a petition for review with the Court of Appeals which
reversed the decisions of the lower courts and ordered petitioners to pay P3,583.50 within
thirty days of finality of the decision, and issued a writ of replevin as regards
the mortgaged vehicle.
9. Hence, the petition at bar.

Issue: WON the petitioners were enriched when respondent obtained insurance coverage for the
mortgaged vehicle under Unjust Enrichment principle of Article 22 of Civil Code.

Ruling:

NO. respondent’s payment of the insurance premiums on behalf of the petitioners did
not unjustly enriched the latter.

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 from August 14, 1996 to August 14, 1997.