Dominion Insurance Corporation v. Court of Appeals

Summary

This case involves an insurance agent's right to reimbursement for claim settlements made from personal funds. Rodolfo Guevarra, agency manager for Dominion Insurance Corporation, sought P156,473.90 representing advances he made to settle insurance claims. While authorized to settle certain claims, his authority was limited to payments from his revolving fund. When Dominion was declared in default for non-appearance at pre-trial, the trial court and Court of Appeals awarded the full amount. However, the Supreme Court, while denying the petition, modified the award to P112,672.11. The Court held that although Guevarra lacked special authority under Article 1878 to pay from personal funds, he could recover under Article 1236 based on unjust enrichment principles, as Dominion benefited from the claim settlements that extinguished its insurance obligations. The decision balances agency law limitations with equitable principles preventing unjust enrichment.