Case Digest (G.R. No. 213582) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 2003, respondent Linda Odiamar Valencia loaned ₱1,400,000.00 to her sister, petitioner Nympha S. Odiamar, evidenced by a promissory note and a real estate mortgage over a parcel in San Jose, Camarines Sur. After petitioner defaulted and remitted only ₱389,951.00, respondent filed a collection suit before the Regional Trial Court (RTC) of San Jose, Camarines Sur, Branch 58. By Decision dated September 28, 2004, the RTC ordered petitioner to pay the remaining balance of ₱1,010,049.00, attorney’s fees of ₱10,000.00, litigation expenses of ₱19,662.78, and costs of suit. On appeal (C.A. G.R. CV No. 93624), the Court of Appeals affirmed on March 16, 2012. Petitioner elevated the case to the Supreme Court (G.R. No. 213582), which, on June 28, 2016, affirmed the appellate court’s ruling with modification on interest. Respondent then filed a Motion for Reconsideration (dated September 1, 2016), praying for the imposition of legal interest on the award and, alternatively, for an Case Digest (G.R. No. 213582) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Loan Agreement
- Petitioner Nympha S. Odiamar borrowed from respondent Linda Odiamar Valencia the principal sum of ₱1,400,000.00.
- Respondent later claimed an indebtedness of ₱2,100,000.00, but the courts below recognized only ₱1,400,000.00 as the original loan.
- Procedural History
- The Regional Trial Court of San Jose, Camarines Sur, Branch 58 awarded respondent the remaining loan balance of ₱1,010,049.00, plus attorney’s fees (₱10,000.00), litigation expenses (₱19,662.78), and costs of suit.
- In C.A. G.R. CV No. 93624, the Court of Appeals affirmed with modification, ordering payment of ₱1,010,049.00.
- On June 28, 2016, the Supreme Court affirmed the CA decision.
- Respondent filed a Motion for Reconsideration dated September 1, 2016, seeking:
- Imposition of legal interest on the monetary award; and
- A declaration that the loan obligation was ₱2,100,000.00.
Issues:
- Whether monetary interest can be imposed on the loan in the absence of a written stipulation.
- Whether compensatory (legal) interest may be imposed on the unpaid loan.
- Whether the original loan obligation is ₱1,400,000.00 or ₱2,100,000.00.
- Whether respondent is entitled to legal interest on the attorney’s fees, litigation expenses, and costs of suit.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)