Locsin II v. Mekeni, G.R. 192105, Dec.

9, 2013

FACTS:

Mekeni Food Corporation is a Philippine company engaged in food manufacturing and

meat processing – offered petitioner Antonio Locsin the position of Regional Sales Manager
including car plan (half paid by company; half paid by him).
Mekeni furnished petitioner with a used Honda Civic car valued at P280,000.00, which
used to be the service vehicle of petitioner’s immediate supervisor. Locsin resigned then, a total
of P112,500.00 had been deducted from his monthly salary and applied as part of the employee’s
share in his car plan.
In his resignation letter, petitioner made an offer to purchase his service vehicle by
paying the outstanding balance thereon. The parties negotiated, but could not agree on the terms
of the proposed purchase. Petitioner thus returned the vehicle to Mekeni.
Mekeni said car plan benefit is applied only to employees who have been with the
company for five years. for this reason, the balance that petitioner should pay on his service
vehicle stood at P116,380.00 if he opts to purchase the same.
Petitioner filed against Mekeni, a complaint for the recovery of monetary claims
consisting of unpaid salaries, commissions, sick/vacation leave benefits, and recovery of monthly
salary deductions which were earmarked for his cost-sharing in the car plan.

ISSUE:

WON there is a quasi-contract created between petitioner and respondent.

RULING:

YES, there is a quasi-contract created between petitioner and respondent.

Under Article 2142 of the Civil Code, “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.”

Here, the SC explained that 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. 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.

Thus, the presence of such instance (called unjust enrichment) it is clear that there is a
quasi-contract created between petitioner and respondent.