Case Digest (G.R. No. 73345)
Facts:
In Social Security System v. Moonwalk Development & Housing Corporation, the Social Security System (SSS) filed a complaint on February 20, 1980 before the Court of First Instance of Rizal against Moonwalk Development & Housing Corporation and its solidary obligors, including Rosita U. Alberto (mother and daughter), JMA House, Inc., and others, for alleged errors in computing the 12% interest on Moonwalk’s delayed loan payments. SSS claimed it failed to apply payments correctly, resulting in an unpaid principal balance of ₱7,053.77 and unpaid penalties of ₱7,517,178.21 as of October 10, 1979. Moonwalk denied liability and contended that SSS had ample opportunity to verify its accounts but did not.During pre-trial, both parties stipulated to the material facts on September 19, 1980, confirming that SSS had approved and released a total of ₱12,254,700.00 in loans between 1971 and 1974; Moonwalk had paid ₱23,657,901.84 against the principal and interest; and SSS issued releases
Case Digest (G.R. No. 73345)
Facts:
- Parties and Origin of the Dispute
- On February 20, 1980, the Social Security System (SSS) sued Moonwalk Development & Housing Corporation (Moonwalk) and its solidary obligors (Rosita U. Alberto mother and daughter, Associated Construction and Surveys Corp., Philippine Model Homes Development Corp., Mariano Z. Velarde, Eusebio T. Ramos) in the CFI of Rizal, Branch XXIX, Pasay City.
- SSS alleged it failed to compute 12% interest on delayed loan payments, leading to:
- An unpaid principal balance of ₱7,053.77.
- Unreflected penalties for delayed payments totaling ₱7,517,178.21 as of October 10, 1979.
- Stipulation of Facts and Procedural History
- By stipulation of September 19, 1980, the parties agreed, inter alia:
- SSS approved a ₱30,000,000 interim loan to Moonwalk on October 6, 1971; ₱9,595,000 released by November 28, 1973; restructured by Third Amended Deed of First Mortgage (Dec. 18, 1973).
- Additional ₱2,659,700 released July 23, 1974; promissory note for ₱12,254,700 executed; Moonwalk paid a total of ₱23,657,901.84.
- SSS issued a Statement of Account (Annex F) and Moonwalk paid ₱15,004,905.74; SSS released mortgages Oct. 9–11, 1979.
- SSS later claimed honest mistake and sought penalties (letters Nov. 28 & Dec. 17, 1979); Moonwalk’s counsel replied Dec. 21, 1979 that obligations were fully paid.
- On October 6, 1980, the trial court dismissed SSS’s complaint, finding the loan and penalties extinguished by full payment and release of mortgages. A motion for reconsideration was denied.
- The Intermediate Appellate Court (IAC) affirmed, focusing the dispute on whether Moonwalk remained liable for unpaid penalties or whether that obligation was extinguished.
Issues:
- Main Issue
- After Moonwalk’s full payment and release of mortgages, is Moonwalk (and its solidary obligors) still liable for the 12% penal clause for late payments, or has that accessory obligation been extinguished along with the principal loan?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)