G.R. No. 219071 - Spouses Reyes vs. Heirs of Malance

Petitioners: Spouses Charito M. Reyes and Roberto Reyes; Spouses Vilma M. Maravillo and Domingo M. Maravillo, Jr. (collectively, the “Magtalas sisters” and their husbands).
Respondents: Heirs of Benjamin Malance—Rosalina M. Malance, Bernabe M. Malance, Bienvenido M. Malance, and Dominga M. Malance—represented by Bienvenido M. Malance (collectively, the “Malançe heirs”).

Benjamin Malance owned a 1.4017-hectare agricultural parcel in Dulong Malabon, Pulilan, Bulacan, covered by Emancipation Patent No. 615124.
On June 26, 2006, he executed a Kasulatan ng Ukol sa Utang for a P600,000 loan from the Magtalas sisters, granting them the right to the fruits of the land for six years or until full payment.

Benjamin died on September 29, 2006. His heirs discovered the Magtalas sisters and their husbands cultivating the land under the Kasulatan.
The Malançe heirs filed a Complaint for Recovery of Possession, Declaration of Nullity of the Kasulatan, and Damages in RTC Branch 84, later amended, alleging Benjamin’s incapacity, forgery of signature, and that the document was simulated.
Petitioners answered, denying allegations, asserting Benjamin was of sound mind, the Kasulatan validly notarized, the dispute agrarian in nature, and that possession could not be recovered without loan repayment.

The RTC initially dismissed the complaint for lack of jurisdiction but later reinstated it and re-raffled to Branch 9.
On August 31, 2010, the RTC upheld the Kasulatan as a valid contract of antichresis, dismissed the complaint for lack of proof of forgery, and declared the Magtalas sisters entitled to retain possession until full payment. The Malançe heirs appealed.

On July 23, 2013, the CA affirmed validity of the Kasulatan, ruled only P218,106.84 was received as proceeds (medical and funeral expenses), and computed the outstanding loan at P4,320.84. It ordered turnover of possession upon payment.
A motion for reconsideration was denied on June 18, 2015. Petitioners filed a Rule 45 petition, raising (a) the CA’s miscalculation of proceeds and (b) whether interest is due without stipulation.

Did the CA err in ruling that only P218,106.84 represented proceeds received by Benjamin from the P600,000 loan?

Is legal interest due on the loan despite no express stipulation in the Kasulatan?