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CD19 - Napocor V Ibrahim

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Christy Canete
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37 views1 page

CD19 - Napocor V Ibrahim

case digest

Uploaded by

Christy Canete
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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CAÑETE, Christy Mae, B.

/ Obligations and Contracts June 01, 2023

Napocor v. Ibrahim
(G.R. No. 175863 (1242) Feb. 18, 2015)

Facts:
In 1978, petitioner NAPOCOR took possession of a parcel of land in Marawi City for
the purpose of building a hydroelectric power plant, believing it was public land
reserved for its use. The land was actually owned by Mangondato, and NAPOCOR
acknowledged the need to compensate him. During the case, the Ibrahims and
Maruhoms claimed ownership of the land covered by TCT No. 378-A. The RTC ruled
that the Ibrahims and Maruhoms were the true owners of the land and were entitled to
compensation, holding Mangondato and NAPOCOR solidarily liable for rental fees and
expropriation indemnity. A notice of garnishment was served on NAPOCOR's
authorized depositary for the amount of P21,801,951.00, which was paid to
Mangondato. NAPOCOR appealed, but the CA affirmed the lower court's decision.

Issue:
Whether NAPOCOR is solidarily liable to the Ibrahims and Maruhoms despite payment
to Mangondato.

Ruling:
No. The Supreme Court held that NAPOCOR's previous payment to Mangondato
extinguished its obligation to pay for the rental fees and expropriation indemnity due
for the subject land. The payment to Mangondato was equivalent to a payment made
in "good faith" to a person in possession of credit under Article 1242 of the Civil Code,
which releases the debtor from its obligation to pay. The Court noted that the payment
was made in the absence of bad faith on NAPOCOR's part and that Article 1242 is an
exception to the rule that a valid payment can only be made to the rightful creditor.
Therefore, NAPOCOR is not solidarily liable to the Ibrahims and Maruhoms for the
rental fees and expropriation indemnity. If the Ibrahims and Maruhoms are the true
owners of the land, they may only recover the rental fees and expropriation indemnity
due from Mangondato up to the amount already received from NAPOCOR. The
extinguishment of NAPOCOR's obligation to pay carries with it legal effects that may
impact the rights of the parties involved. The Court affirmed the CA's decision.

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