UST cooperative vs City of Manila

Facts:
-UST cooperative store is a cooperative association registered
with SEC on 1947
-Their net assets never exceeded P500k.
-RA 2023 was passed on 1957 which made registered
cooperatives with net assets below P500k to be exempted from
all taxes and government fees.
-UST continued paying their taxes since 1957, hence, after
realizing the effects of RA 2023, they filed for the recovery of
their paid taxes.
Issue: Does the City of Manila have the obligation to refund
UST cooperative in the erroneously paid taxes considering that
it was done voluntarily?
Ruling:
-Yes. It is based on equity and good conscience to the person
who paid it. (4 AM. Jur. 514)
PEN:
-The principle of unjust enrichment applies in this case.
-The sources of obligations are the law,contracts, quasicontracts, delict, and quasi-delict. (I think, the rule on recovery
is part of quasi-contracts.)
United Muslim and Christian urban Poor Association Inc. vs
BRYC Dev. Corporation.
Facts:
-SFC owned lot A, B and C.

-UMCUPAI is an organization of squatters who wants to buy lot

A, B and C.
-SFC and UMCUPAI executed a letter of Intent to sell in order to
facilitate the loan approval from Home Mortgage and Finance
Association because such letter is required by the government
authorities who shall approve the loan.
-The loan was not approved.
-UMCUPAI raised its own funds and succeeded in buying lot A
and B.
-UMUPAI failed to pay lot C after the extension granted for
them.
-SFC sold lot C to BRYC.
-UMUPAI wanted to annul the sale and contended that they had
a contract to sell with SFC.
ISSUE: Is the letter of intent to sell or to buy a reciprocal
contract within 1479?
Ruling:
-No. It is only executed to facilitate the approval of the loan.
-Nowhere in the letter of Intent does it state that SFC
relinquishes its title over the subject property upon condition of
complete payment. Hence, it is not a reciprocal contract to
buy/sell.
-The letter is not a promise to buy and sell, it only states the
intention to sell/buy.
PEN:
(Navotas vs. Cruz an accepted unilateral promise to buy/sell
is not binding unless there is option money)
-This case is more recent that Sanchez vs Rigos. Shits about
Sanchez v. Rigos are deemed repealed.