Unjust Enrichment: Meaning
Quick answer
Unjust enrichment means that a person gets or keeps something at the expense of another without a just or legal ground. Article 22 of the Civil Code says that person must return it. The rule covers benefits received through another's act or "any other means", so it is broader than a mistaken payment. Courts look at whether the benefit had a valid basis and whether it came at someone else's loss.
Also called: Unjust enrichment principle, Article 22 of the Civil Code
What does Article 22 say?
Every person who through an act of performance by another, or any other means, acquires or comes into possession of something at the expense of the latter without just or legal ground, shall return the same to him.
See Article 22.
What must be proved?
In BDO Unibank v. Barcellano (2026), the Supreme Court said: "To be applicable, Article 22 requires that: (a) a person is benefited without a valid basis or justification, and (b) such benefit is derived at another's expense or damage." The Court added that the claimant "must clearly establish that another party knowingly received a benefit to which they were not entitled, and that the circumstances render it unjust for that party to retain the benefit."
In Yon Mitori v. Union Bank (2020), the Court stated the same two requisites: "(i) a person is unjustly benefited; and (ii) such benefit is derived at the expense of or with damages to another."
How does it relate to quasi-contracts?
The Civil Code also has quasi-contracts, which are obligations that arise from lawful, voluntary and unilateral acts:
Certain lawful, voluntary and unilateral acts give rise to the juridical relation of quasi-contract to the end that no one shall be unjustly enriched or benefited at the expense of another.
The best known is solutio indebiti under Article 2154: when something is received without a right to demand it and was delivered by mistake, it must be returned.
How have courts applied it?
- In Yon Mitori (2020), a check was credited to a depositor's account early because of a technical error, and the check later bounced. The depositor withdrew the money "fully knowing that he was not entitled thereto." He had to return it.
- In BDO (2026), a bank credited a check as if it were local and let the depositor withdraw before clearing. The Court found the bank grossly negligent, and found that the depositor could reasonably believe in good faith that the money was hers. The bank's claim failed.
Neither case involved a transfer between two private persons, so each new case depends on its own facts.
Example
Made-up illustration: Rhea pays her supplier through a bank transfer but types one wrong digit, and the money goes to Jun, a stranger. Jun sees it and spends it. Jun received money with no legal ground, at Rhea's expense, and knew it was not his. Under Articles 22 and 2154, he has a duty to return it. Whether a court orders the return, and with what interest, depends on the evidence. See Money sent to the wrong account and Legal interest rate in the Philippines.
Which provisions use this term?
Frequently asked questions
What is unjust enrichment?
It is when a person gets or keeps something at the expense of another without just or legal ground. Article 22 of the Civil Code says that person shall return it.
What must be shown for Article 22 to apply?
In BDO Unibank v. Barcellano (2026), the Supreme Court said two things are required: a person is benefited without a valid basis or justification, and the benefit is derived at another's expense or damage.
Is unjust enrichment the same as solutio indebiti?
They are related. Solutio indebiti (Article 2154) is a specific case: something is received without a right to demand it and was delivered by mistake. Article 2142 says quasi-contracts like it exist so that no one is unjustly enriched at the expense of another.
Does the receiver always have to return money credited by mistake?
Not in every case. In Yon Mitori v. Union Bank (2020), a depositor who used funds knowing he was not entitled to them had to return them. In BDO (2026), the bank lost its claim because it was grossly negligent and did not show that the depositor knowingly received a benefit she was not entitled to.
General information, not legal advice. For your case, ask a lawyer, the Public Attorney's Office (PAO) or the agency.
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