Title
Bernal vs. Villaflor
Case
G.R. No. 213617
Decision Date
Apr 18, 2018
Dispute over unpaid construction sums; SC ruled 6% interest on P1.71M from CA decision date (Feb 14, 2014) until full payment.
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Case Digest (G.R. No. 213617)

Facts:

Background of the Case:

  • The case involves a dispute over unpaid sums related to the construction of a Medical Arts Building in Caranglaan District, Dagupan City. The petitioner, Architect Eusebio B. Bernal, doing business as Contemporary Builders, was engaged by the respondents, Dr. Vivencio Villaflor and Dra. Gregoria Villaflor, for the construction project in 1995.

RTC Decision:

  • On January 28, 2009, the Regional Trial Court (RTC) of Dagupan City ruled in favor of the petitioner, ordering the respondents to pay P2,848,000.00 plus legal interest from March 4, 2008, until full payment, and P200,000.00 as attorney’s fees. The RTC dismissed all other claims and counterclaims.

CA Decision:

  • The respondents appealed to the Court of Appeals (CA), which modified the RTC’s decision on February 14, 2014. The CA reduced the total award to P1,710,271.21, with legal interest at 6% per annum from the date of finality of judgment until full satisfaction. The CA affirmed the award of attorney’s fees and the dismissal of counterclaims.

Petitioner’s Argument:

  • The petitioner filed a petition for review, contesting the CA’s computation of interest. He argued that interest should be computed at 6% per annum from the time of extrajudicial demand (July 5, 1998) or judicial demand (November 16, 1998), plus 12% per annum from the date of judgment until full payment.

Issue:

  1. Whether the interest on the monetary award should be computed from the date of extrajudicial or judicial demand, or from the date of finality of the judgment.
  2. Whether the interest rate should be 6% or 12% per annum after the judgment becomes final and executory.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

  • The Supreme Court modified the CA Decision, ruling that the interest of 6% per annum on the award of P1,710,271.21 shall be computed from February 14, 2014, until full payment.


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