Short answer. Yes. Article 2143 of the Civil Code expressly states that the enumerated quasi-contract provisions do not exclude other quasi-contracts that fall within the general principle of unjust enrichment. If someone was unjustly enriched at your expense, you may have a valid claim even if the exact situation has no named provision.
What the law says
The provisions for quasi-contracts in this Chapter do not exclude other quasi-contracts which may come within the purview of the preceding article.
Civil Code, Article 2143 — Other Quasi-Contracts. Read the full provision →
What Article 2143 does
The Civil Code names specific quasi-contracts — negotiorum gestio (managing another's affairs without authority) and solutio indebiti (recovering a payment made by mistake). Article 2143 makes clear that these named forms are not exhaustive. It states that the provisions for quasi-contracts in this Chapter do not exclude other quasi-contracts which may come within the purview of the preceding article. The 'preceding article' refers to the general rule against unjust enrichment: no one may unjustly enrich himself at the expense of another. This creates an open category that courts can apply to factual situations the drafters did not anticipate.
The general rule behind all quasi-contracts
A quasi-contract is not a real contract — nobody agreed to anything. The law creates an obligation anyway to prevent one person from being unjustly enriched at another's expense. The two named quasi-contracts are simply the most common applications. Article 2143 preserves the flexibility to treat unusual situations the same way, as long as the underlying facts fit: one party received a benefit, another party provided it, and there was no lawful reason for the enrichment to go uncompensated. The claim rests on equity, not on any prior agreement.
What you still need to show
The open category under Article 2143 is not a blank check. You still need to establish three things: that the other party was enriched, that your own assets were diminished or that you incurred cost, and that there is a direct connection between the two — the enrichment came at your expense. You also need to show there was no contract, no law, and no other legal basis that already governs the situation. If a contract exists between the parties, quasi-contract does not apply; the contract controls.
How this plays out in practice
Situations where Article 2143 becomes relevant tend to involve grey areas — a payment sent to the wrong account that was spent before the bank noticed, expenses paid on behalf of an absent person under ambiguous authority, or a benefit conferred during failed contract negotiations. Because the named quasi-contracts do not cover every permutation of these scenarios, Article 2143 gives courts room to rule that the person who benefited is obliged to return the value, even without a statutory provision that fits the exact facts. If you believe you are in this situation, the first step is gathering evidence of the benefit received and the expense you bore.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Metropolitan Bank & Trust Company vs. Absolute Management Corporation, G.R. No. 170498, January 9, 2013 — read the decision on LawPhil →
- Claudio delos Reyes, et al. vs. Court of Appeals, et al, G.R. No. 129103, September 3, 1999 — read the decision on LawPhil →