Aniano Obaa vs Court of Appeals

135 SCRA 557 Civil Law Law on Sales Contract of Sale Ownership Rescissible Contract
Unjust Enrichment
On November 21, 1964, Chan Lin offered to buy 170 cavans of rice from Aniceto Sandoval at
P37.25/sack (P6,332.50). Sandoval agreed; so from Rosales, Pangasinan, Chan Lin accompanied
Sandovals driver to have the rice be delivered to San Fernando, La Union. Upon arriving, the sacks of
rice were unloaded but when Sandovals driver tried to collect the payment, Chan Lin was nowhere to be
found. The driver then tried to collect from Aniano Obaa, who was the owner of the store 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 Anianos 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 Anianos money. Aniano claimed that he then returned the cavans of
rice to Sandoval. But Sandovals 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withdrawn the replevin case had the sacks of rice been returned.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.