Case Digest (G.R. No. 195166)
Facts:
In Spouses Salvador and Alma Abella v. Spouses Romeo and Annie Abella (G.R. No. 195166, July 8, 2015), petitioners Salvador and Alma Abella extended a sum of ₱500,000.00 to respondents Romeo and Annie Abella under an acknowledgment receipt dated March 22, 1999, stipulating repayment within one year “with interest.” Respondents thereafter remitted ₱200,000.00 in two payments but failed to settle the ₱300,000.00 balance. On July 31, 2002, petitioners filed Civil Case No. 6627 for sum of money and damages in the RTC of Kalibo, Aklan. Respondents countered that the transaction was a joint venture, not a simple loan, and that the ₱300,000.00 balance remained unpaid only because collections yielded just ₱200,000.00. In its December 28, 2005 decision, the trial court held the contract to be a simple loan, ordered respondents to pay the ₱300,000.00 balance at 30% per annum interest from July 31, 2002, plus litigation expenses and attorney’s fees, and dismissed respondents’ counterclaim.Case Digest (G.R. No. 195166)
Facts:
- Parties and Instrument
- Petitioners Spouses Salvador and Alma Abella extended P500,000.00 to respondents Spouses Romeo and Annie Abella on March 22, 1999 by way of an acknowledgment receipt stating the sum was “payable within one (1) year from date hereof with interest.”
- Respondents acknowledged receipt, admitted two payments of P100,000.00 each (June 30, 2001 and December 30, 2001), and claimed to have paid monthly “interest” at 2.5%.
- Respondents’ Counterclaim and Characterization
- Respondents asserted the P500,000.00 was capital for a joint venture: petitioners would receive 2.5% per month, respondents a 2.5% service fee, and the one-year term was merely an exit period if unprofitable.
- They alleged the joint venture yielded only P200,000.00 in collections, leaving P300,000.00 unpaid.
- Procedural History
- On July 31, 2002, petitioners filed Civil Case No. 6627 for sum of money and damages; respondents answered with counterclaim and motion to dismiss.
- The Regional Trial Court (Dec. 28, 2005) ruled in favor of petitioners: P300,000.00 principal plus 30% per annum interest from July 31, 2002, litigation expenses, and attorney’s fees. Motion for reconsideration denied (Mar. 13, 2006).
- On appeal, the Court of Appeals (Sept. 30, 2010) reversed: held no valid interest rate was stipulated, treated all payments as principal, found overpayment of P148,500.00, and ordered petitioners to refund that amount with 6% interest from decision and 12% upon finality. Motion for reconsideration denied (Jan. 4, 2011).
- Petitioners filed a Rule 45 petition before the Supreme Court seeking reversal of the Court of Appeals decision and enforcement of 2.5% monthly interest plus remaining balance.
Issues:
- Whether interest accrued on respondents’ loan from petitioners; if so, at what rate?
- Whether petitioners are liable to reimburse respondents for alleged excess payments and to pay interest thereon.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)