Hyatt Elevators v. Cathedral Heights Building Complex Association

Summary

This case involves a contractual dispute between Hyatt Elevators and Cathedral Heights Building Complex Association over payment for elevator spare parts. Hyatt maintained Cathedral Heights' elevators under a 1994 Service Agreement requiring payment for additional repair parts. From 1997-1998, Hyatt installed parts worth P1,161,933.47 but was not paid. The RTC ruled for Hyatt based on sales invoices proving a contract of sale. The CA reversed, finding no perfected contract due to lack of consent and price agreement, since no purchase orders were issued. The Supreme Court ultimately ruled that while no contract of sale existed, denying payment would unjustly enrich Cathedral Heights who benefited from the repairs. The Court applied quasi-contract principles under Civil Code Article 2142, noting that respondent's employees acknowledged the installations and the elevators were operational due to Hyatt's work. The decision demonstrates the application of unjust enrichment doctrine when formal contractual requirements are not met but one party benefits from another's performance.