- Petitioner
- Philippine Stock Exchange
- Respondent
- Antonio K. Litonjua
- Citation
- G.R. No. 204014
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Perez, J.
- Decided
- December 5, 2016
Summary
The Litonjua Group paid P19,000,000 to PSE for settlement of Trendline Securities' obligations as part of acquiring Trendline's trading seat membership. Despite receiving payment with annotation as full settlement, PSE failed to lift Trendline's suspension and later refused to refund the money. The Supreme Court held PSE liable to return the payment under principles of unjust enrichment and estoppel. Although PSE was not party to the letter-agreement due to lack of board resolution, it led the Litonjua Group to believe the payment would effect full settlement. PSE cannot claim non-party status while retaining benefit of payment. The Court applied Article 22 of the Civil Code on unjust enrichment, finding PSE benefited without valid justification at Litonjua Group's expense. Exemplary damages were awarded for PSE's reckless conduct in refusing refund despite lacking legal right to retain money. The decision demonstrates application of quasi-contractual remedies and equitable principles in commercial transactions.