Case Digest (G.R. No. 169108) Core Legal Reasoning Model
Facts:
In the case of Spouses Roque and Fatima Ting v. Commission on Audit and City of Cebu (G.R. No. 254142), the petitioners, represented by Santiago J. Tanchan, Jr., sought a certiorari review under Rule 64, in relation to Rule 65 of the Rules of Court, against the respondents, consisting of the Commission on Audit (COA) and the City of Cebu. This action stemmed from a dispute regarding a judgment award stemming from Civil Case No. CEB-26607, wherein the Regional Trial Court (RTC) of Cebu had rendered a decision on January 3, 2008, in favor of the petitioners against the City of Cebu. The city was ordered to pay the petitioners a total of Php37,702,500 for the value of demolished properties, with interest accruing at a rate of six percent (6%) annually from the date of judgment until full payment was made.
The chronology of events includes the City of Cebu's entry into a Memorandum of Agreement with the petitioners on September 7, 1997, for the exchange of lots which was not f
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Case Digest (G.R. No. 169108) Expanded Legal Reasoning Model
Facts:
- Background of the Case
- The petitioners are Spouses Roque and Fatima Ting, represented by their attorney-in-fact Santiago J. Tanchan, Jr.
- The respondents are the Commission on Audit (COA) and the City Government of Cebu.
- Transaction and Earlier Dispute
- The Metro Cebu Development Project (MCDP) III, created by the City of Cebu to manage its road widening projects, was responsible for overseeing the Cebu South Reclamation Project.
- On September 7, 1997, Mr. Samuel B. Darza, the Project Director of MCDP III, entered into a Memorandum of Agreement with the petitioners for the exchange of lots.
- Under the agreement, MCDP III was to substitute its Lot C-1 (4,753 sq m) with petitioners’ Lots Nos. 7-A and 7-B, having areas of 1,643 sq m and 2,588 sq m respectively.
- Around 1999, the petitioners’ lots were demolished although the exchange of lots had not yet occurred, prompting further dispute.
- Litigation in the Regional Trial Court (RTC)
- Petitioners filed a case for Specific Performance and Damages against the City of Cebu, which was docketed as Civil Case No. CEB-26607.
- On January 3, 2008, the RTC rendered a decision in favor of the petitioners awarding:
- Php33,700,000.00 for the value of Lot Nos. 7-B and 7-C.
- Php3,912,500.00 for the value of the demolished warehouses and resthouse.
- Php60,000.00 as attorney’s fees and Php30,000.00 as litigation expenses.
- Interest on these amounts at 6% per annum from the date of judgment until full payment.
- Appellate Proceedings and Final Judgment
- The City of Cebu elevated the case to the Court of Appeals (CA) which, on November 26, 2013, denied the appeal (CA-G.R. CV No. 02496).
- A motion for reconsideration filed by the City was also denied by the CA on May 12, 2014.
- After the appeal before the Supreme Court was denied on July 30, 2014 (G.R. No. 212842), an Entry of Judgment was issued confirming that the case became final and executory on March 9, 2015.
- COA Proceedings on the Money Claim
- Petitioners filed a petition for money claim before the COA seeking payment of the judgment award amounting to Php37,702,500.00 along with interest at 6% per annum from the RTC decision date (January 3, 2008) until full payment.
- On May 21, 2019, the COA issued Decision No. 2019-129, which partially granted the money claim:
- The City of Cebu was ordered to pay Php37,702,500.00 plus interest computed at 6% per annum.
- However, the reckoning of interest was fixed from May 23, 2017 (the day after the filing of the money claim) instead of from the RTC judgment date or the date the judgment became final.
- On January 21, 2020, the COA promulgated Resolution No. 2020-042 denying the petitioners’ motion for partial reconsideration on the same grounds.
Issues:
- Jurisdiction and Power of the COA
- Whether the COA acted without or in excess of its jurisdiction or with grave abuse of discretion in modifying the final and executory decision of the RTC by changing the date from which interest should be reckoned—from the RTC’s final judgment date (or its finality) to the date of filing the money claim before the COA.
- Proper Reckoning of Legal Interest
- Whether the legal interest on the judgment award should commence from January 3, 2008 (or from the date the judgment became final on March 9, 2015) rather than from May 23, 2017, as decided by the COA.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)