E.J. Smith v. Jacinta Lopez

Summary

This 1905 case involved a contractual dispute over payment for sanitary installation work performed at defendants' house pursuant to Board of Health orders. Smith and Reyes sued the Lopez sisters for 3,270 pesos for installing water systems and bathroom fixtures, claiming their father Nicasio Lopez contracted the work as property administrator. The Supreme Court applied quasi-contract principles under Civil Code Articles 1887-1893, finding defendants liable for house improvements that benefited them, even without express authorization. However, since defendants owned only half the house (the other half belonging to a deceased co-owner's heirs), the Court reduced the judgment to half the reasonable value (1,358.70 pesos), requiring a separate action against the other co-owner's estate. The decision established important precedents on implied agency, quasi-contracts, unjust enrichment, and co-ownership liability for property improvements.