Title
Supreme Court
Spouses Ting vs. Commission on Audit
Case
G.R. No. 254142
Decision Date
Jul 27, 2021
A dispute over property exchange led to a final RTC judgment favoring petitioners. COA modified interest reckoning, but SC ruled COA overstepped, affirming interest from judgment finality.

Case Summary (G.R. No. 254142)

Background of the Case

On September 7, 1997, the MCDP III, through its Project Director Samuel B. Darza, entered into a Memorandum of Agreement with the petitioners for the exchange of lots. The MCDP III was to replace its Lot C-1 with two lots owned by the petitioners. However, in 1999, the MCDP III demolished the petitioners' properties without completing the exchange, prompting them to file a case for Specific Performance and Damages against the City of Cebu, designated as Civil Case No. CEB-26607.

Regional Trial Court Decision

On January 3, 2008, the Regional Trial Court (RTC) ruled in favor of the petitioners, ordering the City of Cebu to pay Php33,700,000 for the value of the petitioners’ lots, Php3,912,500 for demolished structures, as well as attorney’s fees and litigation expenses. The RTC decision provided for a six percent (6%) annual interest on the judgment from the date of the decision until full payment.

Court of Appeals Proceedings

The City of Cebu appealed the RTC decision to the Court of Appeals (CA), which denied the appeal on November 26, 2013, affirming the RTC’s ruling. The CA’s Resolution affirming the denial of the motion for reconsideration further solidified the petitioners' entitlement to the judgment award. An Entry of Judgment issued on March 9, 2015, indicated that the case had become final and executory.

Petition for Money Claim

Subsequently, the petitioners submitted a petition for money claim to the COA, seeking payment of the judgment award plus interest from January 3, 2008, until fully paid. The financial claim amounted to Php37,702,500. The COA issued Decision No. 2019-129 on May 21, 2019, which partially granted the money claim but specified that interest would only be calculated from May 23, 2017, the day after the money claim was filed with the COA.

COA's Rationale

The COA reasoned that the petitioners caused the delay in filing the money claim, which necessitated the limitation on the interest accrual to begin from May 23, 2017. In the COA's subsequent Resolution No. 2020-042, the petitioners' motion for partial reconsideration was denied, asserting that there were insufficient grounds to alter the decision.

Petitioners’ Arguments

The petitioners contended that the COA exceeded its jurisdiction and acted with grave abuse of discretion by amending the RTC’s final judgment by changing the reckoning date for the calculation of interest. They argued that the legal interest should be calculated from the date of the RTC's judgment on January 3, 2008.

Solicitor General's Position

The Office of the Solicitor General, representing the COA, acknowledged that the COA had erred and committed grave abuse of discretion when it set the reckoning date for the interest to May 23, 2017. They concurred that the legal interest should instead be reckoned from March 9, 2015, when the RTC decision became final and exec

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