Dometila M. Andres v. Manufacturers Hanover & Trust Corporation

Summary

This Supreme Court case involved a duplicate remittance payment where garment manufacturer Dometila Andres received the same $10,000 twice due to miscommunication between banks. When Manufacturers Hanover & Trust Corporation sought recovery of the duplicate payment, petitioner refused, claiming entitlement based on outstanding receivables from her US client. The Court applied Article 2154 of the Civil Code (solutio indebiti doctrine), ruling that the bank could recover the mistakenly paid amount since there was no contractual relationship between the bank and petitioner that would justify retention. The decision reinforced the principle against unjust enrichment and established that specific Civil Code provisions prevail over equitable common law principles. The case demonstrates the application of quasi-contract principles in commercial banking disputes involving international remittances.