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G.R. No. L-36249: ANIANO OBAÑA vs. THE COURT OF APPEALS AND ANICETO
SANDOVAL
1985 March 29, 135 scra 557
Contract of Sale – Ownership – Rescissible Contract – Unjust Enrichment

On November 21, 1964, Chan Lin offered to buy 170 cavans of rice from Sandoval at
P37.25/sack (P6332.50). Sandoval agreed so from Rosales, Pangasinan, Chan Lin
accompanied Sandoval’s driver to have the rice be delivered to San Fernando, La Union. Upon
arriving, the sacks of rice were unloaded but when Sandoval’s driver tried to collect the
payment, Chan Lin was nowhere to be found. The driver then tried to collect from Aniano, who
was the storeowner where they unloaded the rice. But Aniano refused to pay, saying that he
made the payment to Chan Lin for P33/cavan and that he will not return the sacks of rice to
Sandoval as they were paid already. Apparently, Aniano and Chan Lin had an earlier agreement
that Chan Lin will sell him 170 cavans of rice for P33 each. Aniano said Chan Lin swindled
Sandoval. Sandoval filed for replevin.

ISSUE: Who is the rightful owner of the 170 cavans of rice?

HELD: Ownership was transferred to Chan Lin when the cavans of rice were delivered to
Aniano’s store. This was agreed upon in the contract between Sandoval and Chan Lin.
However, it was found that 3 days after the delivery, Chan Lin returned Aniano’s money. Aniano
claimed that he then returned the cavans of rice to Sandoval. But Sandoval’s driver said Aniano
never returned the sacks of rice. They would have withdrawn the replevin case had the sacks of
rice been returned. Sandoval has all the right to recover the rice and rescind the contract as he
was not paid. Aniano cannot unjustly enrich himself at the expense of Sandoval.