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EASTERN SHIPPING LINES v. CA

This case has been cited 161 times or more.

	GR NO. 166873 2007-04-27	GEMMA ILAGAN v. PEOPLE CARPIO MORALES, J.
The lack of criminal liability of petitioners then notwithstanding, they are civilly liable in the amount of P470,350, to bear 12% interest from the filing of the information on January 30, 2002 up to the time it is fully paid.[31]
	GR NO. 150066 2007-04-13	SPS. EMMANUEL AND EDNA CHUA AND SPS. MANUEL AND MARIA CHUA v. MSGR. VIRGILIO SORIANO. SUBSTITUTED BY SISTER MARY VIRGILIA CELESTINO SORIANO AUSTRIA-MARTINEZ, J.
x x x, the general rule that the direct result of a previous void contract cannot be valid, is inapplicable in this case as it will directly contravene the Torrens system of registration. Where innocent third persons, relying on the correctness of the certificate of title thus issued, acquire rights over the property, the court cannot disregard such rights and order the cancellation of the certificate. The effect of such outright cancellation will be to impair public confidence in the certificate of title. The sanctity of the Torrens system must be preserved; otherwise, everyone dealing with the property registered under the system will have to inquire in every instance as to whether the title had been regularly or irregularly issued, contrary to the evident purpose of the law.[47] Being purchasers in good faith, the Chuas already acquired valid title to the property. A purchaser in good faith holds an indefeasible title to the property and he is entitled to the protection of the law. Accordingly, TCT No. 14514 issued in the name of the Chuas is valid. The amount of P500,000.00, representing the purchase price in the Absolute Deed of Sale[48] dated July 4, 1989, which the RTC directed Celestino to pay to the Chuas should instead be paid to Soriano as part of the actual damages awarded to him. Such amount shall earn interest rate of 6% from August 20, 1990, the time of the filing of the complaint until its full payment before finality of judgment. After the judgment becomes final and executory until the obligation is satisfied, the amount due shall earn interest at 12% per year, the interim period being deemed equivalent to a forbearance of credit.[49]
	GR NO. 163359 2007-03-06	INDUSTRIAL TECHNOLOGY DEVELOPMENT INSTITUTE REP. BY DR. RUFINO C. LIRAG v. RUFINO M. VILLANUEVA TINGA, J.
As a final note, we deem it best, in the interest of justice, not to award interest in the concept of actual damages on the total amount due to RMVC. This case was first filed in 1993. The parties have been locked in a long and protracted legal battle for 14 years due to no fault on the part of ITDI. To require it to pay interest on the amount due to RMVC from the time of the filing of the Amended Complaint would be unwarranted and unjust.[30] Thus, interest at the rate of twelve percent (12%) per annum on the award of actual damages in the amount of P33,909.97 and cost of construction materials in the amount of P713,992.00 should be imposed only upon the finality of the judgment of this Court.[31]
	GR NO. 126890 2006-11-28	UNITED PLANTERS SUGAR MILLING COMPANY v. CA CARPIO, J.
(4) On the payment of interest, the 12% rate the trial court imposed applies only when the obligation breached consists in the payment of a sum of money i.e. forbearance of money, in the absence of a stipulation. Otherwise the applicable rate is 6% per annum.[47] Thus, except for UPSUMCO's bank deposits in (1) PNB Dumaguete and Escolta and (2) the Rural Banks of Bais City and Manjuyod, which being forbearance in money, are subject to interest rates of 10%[48] and 12%[49] per annum, respectively, the interest rate on all the other monetary awards to UPSUMCO should be reduced to 6% per annum. Upon the finality of this ruling, the rate of interest shall be 12% per annum for the entire judgment, until its satisfaction.[50]
	GR NO. 74269 2006-11-27	SOLID HOMES v. IAC TINGA, J.
This precise issue was subsequently addressed by this Court in Eastern Shipping Lines, Inc. vs. Court of Appeals.[23] Although the filing of petition in G.R. No. 74269 preceded Eastern Shipping, the guidelines laid down therein are applicable to this case as they implemented and clarified laws that were already in existence even before this instant petition was filed.[24]
	GR NO. 149753 2006-11-27	MIGUEL COSME v. PEOPLE AUSTRIA-MARTINEZ, J.
As to the rate of interest, the guidelines laid down in Eastern Shipping lines, Inc. v. Court of Appeals[39] are applicable to the present case, to wit: When an obligation, regardless of its source, i.e., law contracts, quasi-contracts, delicts or quasi-delicts is breached, the contravenor can be held liable for damages. The provisions under Tile XVIII on "Damages" of the Civil Code govern in determining the measure of recoverable damages.
	GR NO. 152948 2006-09-27	ALMEDA DEVELOPMENT v. METRO MOTORS SALES INC. CARPIO MORALES, J.
Since, contrary to petitioners' claim, respondents did not willfully, maliciously, and persistently renege on their obligation to deliver the vehicle, the Court of Appeals did not err in holding that these were no sufficient evidence of bad faith. The appellate court's deletion of the award of moral and exemplary damages, attorney's fees and litigation expenses was thus in order.[15] And so was its reduction of the interest rate from 12% to 6%, it being in accordance with the guideline laid down in Eastern Shipping Lines, Inc. v. Court of Appeals[16] on the imposition of interest on actual or compensatory damages arising from a breach of an obligation, not constituting a loan or forebearance of money, to wit:x x x x
	GR NO. 147791 2006-09-08	CONSTRUCTION DEVELOPMENT CORPORATION OF PHILIPPINES v. REBECCA G. ESTRELLA YNARES-SANTIAGO, J.
Regarding the imposition of legal interest at the rate of 6% from the time of the filing of the complaint, we held in Eastern Shipping Lines, Inc. v. Court of Appeals,[30] that when an obligation, regardless of its source, i.e., law, contracts, quasi- contracts, delicts or quasi-delicts is breached, the contravenor can be held liable for payment of interest in the concept of actual and compensatory damages,[31] subject to the following rules, to wit -
	GR NO. 152202 2006-07-28	CRISOSTOMO ALCARAZ v. CA PUNO, J.
It is, however, undeniable that petitioner Alcaraz accumulated unpaid obligations both in his peso and dollar accounts through the use of the credit card issued to him by private respondent Equitable. As such, petitioner Alcaraz is liable for the payment thereof. Since the provisions of the Terms and Conditions are inapplicable to petitioner Alcaraz, the legal interest on obligations consisting of loan or forbearance of money shall apply. As this Court ruled in the landmark case of Eastern Shipping Lines, Inc. v. Court of Appeals,[31] to wit: When the obligation is breached, and it consists in the payment of a sum of money, i.e., a loan or forbearance of money, the interest due should be that which may have been stipulated in writing. Furthermore, the interest due shall itself earn legal interest from the time it is judicially demanded. In the absence of stipulation, the rate of interest shall be 12% per annum to be computed from default, i.e., from judicial or extrajudicial demand under and subject to the provisions of Article 1169 of the Civil Code.[32]
	GR NO. 152202 2006-07-28	CRISOSTOMO ALCARAZ v. CA PUNO, J.
When the obligation is breached, and it consists in the payment of a sum of money, i.e., a loan or forbearance of money, the interest due should be that which may have been stipulated in writing. Furthermore, the interest due shall itself earn legal interest from the time it is judicially demanded. In the absence of stipulation, the rate of interest shall be 12% per annum to be computed from default, i.e., from judicial or extrajudicial demand under and subject to the provisions of Article 1169 of the Civil Code.[32]
	GR NO. 151890 2006-06-20	PRUDENTIAL GUARANTEE v. TRANS-ASIA SHIPPING LINES CHICO-NAZARIO, J.
An interest of 12% per annum is similarly imposed on the TOTAL amount of liability adjudged in section III herein, computed from the time of finality of judgment until the full satisfaction thereof in conformity with this Court's ruling in Eastern Shipping Lines, Inc. v. Court of Appeals. This Court in Eastern Shipping Lines, Inc. v. Court of Appeals,[47] inscribed the rule of thumb[48] in the application of interest to be imposed on obligations, regardless of their source. Eastern emphasized beyond cavil that when the judgment of the court awarding a sum of money becomes final and executory, the rate of legal interest, regardless of whether the obligation involves a loan or forbearance of money, shall be 12% per annum from such finality until its satisfaction, this interim period being deemed to be by then an equivalent to a forbearance[49] of credit.
	GR NO. 146918 2006-05-02	CITIBANK v. SPS. LUIS AND CARMELITA CABAMONGAN AND THEIR SONS LUIS CABAMONGAN AUSTRIA-MARTINEZ, J.
The applicable interest rate on the actual damages of $55,216.69, should be in accordance with the guidelines set forth in Eastern Shipping Lines, Inc. v. Court of Appeals[49] to wit: When an obligation, regardless of its source, i.e., law, contracts, quasi-contracts, delicts or quasi-delicts is breached, the contravenor can be held liable for damages. The provisions under Title XVIII on "Damages" of the Civil Code govern in determining the measure of recoverable damages.
	GR NO. 139762 2006-04-26	RADIO COMMUNICATIONS OF PHILIPPINES v. CA YNARES-SANTIAGO, J.
RCPI next contends that the trial court erred in imposing a 12% per annum interest rate on the amount awarded to Villalon. It claims that pursuant to the ruling in Eastern Shipping Lines, Inc. v. Court of Appeals,[13] the proper interest rate is 6% per annum because the money judgment in the instant case does not involve a loan or forbearance of money.
	GR NO. 163269 2006-04-19	ROLANDO C. RIVERA v. PROMULGATED: SOLIDBANK CORPORATION CALLEJO, SR., J.
Respondent maintains that courts have no power to relieve parties of obligations voluntarily entered into simply because their contracts turned out to be disastrous deeds. Citing the ruling of this Court in Eastern Shipping Lines, Inc. v. Court of Appeals,[26] respondent avers that petitioner is obliged to pay 12% per annum interest of the P963,619.28 from judicial or extrajudicial demand.
	GR NO. 168736 2006-04-19	SPS. ADELINA S.CUYCO AND FELICIANO U. CUYCO v. SPS. RENATO CUYCO AND FILIPINA CUYCO YNARES-SANTIAGO, J.
The foregoing provision has been incorporated in the comprehensive summary of existing rules on the computation of legal interest enunciated by the Court in Eastern Shipping Lines, Inc. v. Court of Appeals,[20] to wit: When an obligation is breached, and it consists in the payment of a sum of money, i.e., a loan or forbearance of money, the interest due should be that which may have been stipulated in writing. Furthermore, the interest due shall itself earn legal interest from the time it is judicially demanded. In the absence of stipulation, the rate of interest shall be 12% per annum to be computed from default, i.e., from judicial or extrajudicial demand under and subject to the provisions of Article 1169 of the Civil Code.
	GR NO. 163075 2006-01-23	AYALA LIFE ASSURANCE v. RAY BURTON DEVELOPMENT CORPORATION SANDOVAL-GUTIERREZ, J.
The Court of Appeals further held that with respect to the award of interest, petitioner is liable to pay interest of 12% per annum upon the net refundable amount due from the time respondent made the extrajudicial demand upon it on August 12, 1998 to refund payment under the Contract to Sell,[16] pursuant to our ruling in Eastern Shipping Lines, Inc. v. Court of Appeals.[17]
	GR No. 145578 2005-11-18	JOSE C. TUPAZ IV v. CA CARPIO, J.
The lower courts correctly applied the 18% interest rate per annum considering that the face value of each of the trust receipts is based on the drafts drawn under the letters of credit. Based on the guidelines laid down in Eastern Shipping Lines, Inc. v. Court of Appeals,[23] the accrued stipulated interest earns 12% interest per annum from the time of the filing of the Informations in the Makati Regional Trial Court on 17 January 1984. Further, the total amount due as of the date of the finality of this Decision will earn interest at 18% per annum until fully paid since this was the stipulated rate in the applications for the letters of credit.[24]
	GR NO. 151352 2005-08-29	LETICIA T. FIDELDIA v. SPS. RAY AND GLORIA SONGCUAN CARPIO, J.
As the Court of Appeals correctly noted, the trial court in the specific performance case should have ordered Leticia to execute the necessary deed of conveyance in favor of the Spouses Songcuan and deliver the titles to the properties. Although Petra had already donated the properties to Leticia, Leticia is bound by the outcome of the specific performance case by virtue of the notice of lis pendens annotated on the titles to the properties. Petra is also liable to pay the legal interest on the amount of damages awarded by the trial court, as modified by the Court of Appeals, in favor of the Spouses Songcuan.[29]
	GR No. 151352 2005-07-29	LETICIA T. FIDELDIA v. SPS. RAY AND GLORIA SONGCUAN CARPIO, J.
As the Court of Appeals correctly noted, the trial court in the specific performance case should have ordered Leticia to execute the necessary deed of conveyance in favor of the Spouses Songcuan and deliver the titles to the properties. Although Petra had already donated the properties to Leticia, Leticia is bound by the outcome of the specific performance case by virtue of the notice of lis pendens annotated on the titles to the properties. Petra is also liable to pay the legal interest on the amount of damages awarded by the trial court, as modified by the Court of Appeals, in favor of the Spouses Songcuan.[29]
	GR No. 161833 2005-07-08	PHILIPPINE CHARTER INSURANCE CORPORATION v. UNKNOWN OWNER OF VESSEL M/V 'NATIONAL R CALLEJO, SR., J.
The petitioner insists that the respondents did not observe extraordinary diligence in the care of the goods. It argues that in the performance of its obligations, the respondent ICTSI should observe the same degree of diligence as that required of a common carrier under the New Civil Code of the Philippines. Citing Eastern Shipping Lines, Inc. v. Court of Appeals,[38] it posits that respondents are liable in solidum to it, inasmuch as both are charged with the obligation to deliver the goods in good condition to its consignee, BMICI.
	GR NO. 154973 2005-06-21	PRESIDENT OF PHILIPPINE DEPOSIT INSURANCE CORPORATION AS LIQUIDATOR OF PACIFIC BANKING CORPORATION v. WILFREDO D. REYES DAVIDE, JR., C.J.
As for the second and third issues, the Liquidator argues that no actual damages can arise from the closure of the bank. The ruling in Eastern Shipping Lines, Inc. v. Court of Appeals[13] is not applicable because that case clearly refers to an award of interest in the concept of actual and compensatory damages in case of breach of an obligation. The failure of PaBC to return the Singaporeans' equity investment because of its closure is not a breach of an obligation the closure being akin to a force majeure. If indeed PaBC is liable to the Singaporeans for actual and compensatory damages, accrual thereof should be reckoned from the date of demand pursuant to Article 1169 of the Civil Code. Instead of running from 15 October 1981 when the Singaporeans bought their shares in PaBC, the 6% interest rate should be reckoned from 26 June 1992, the date the Singaporeans filed their claim in the liquidation court.
	GR NO. 117456 2005-05-06	GAMBOA v. CA CORONA, J.
In the case of Eastern Shipping Lines, Inc. v. Court of Appeals,[16] this Court, through the Honorable Justice Jose C. Vitug, suggested the following rules of thumb: When an obligation, regardless of its source, i.e., law, contracts, quasi-contracts, delicts or quasi-delicts is breached, the contravenor can be held liable for damages. The provisions under Title XVIII on "Damages" of the Civil Code govern in determining the measure of recoverable damages.
	GR NO. 140182 2005-04-12	TANAY RECREATION CENTER v. CATALINA MATIENZO FAUSTO+ AUSTRIA-MARTINEZ, J.
Such award of damages shall earn interest at the legal rate of six percent (6%) per annum, which shall be computed from the time of the filing of the Complaint on August 22, 1991, until the finality of this decision. After the present decision becomes final and executory, the rate of interest shall increase to twelve percent (12%) per annum from such finality until its satisfaction, this interim period being deemed to be equivalent to a forbearance of credit.[52] This is in accord with the guidelines laid down by the Court in Eastern Shipping Lines, Inc. vs. Court of Appeals,[53] regarding the manner of computing legal interest, viz.:II. With regard particularly to an award of interest in the concept of actual and compensatory damages, the rate of interest, as well as the accrual thereof, is imposed, as follows:
	GR NO. 160533 2005-01-12	FIRST FIL-SIN LENDING CORPORATION v. GLORIA D. PADILLO YNARES-SANTIAGO, J.
The same promissory note provides that "x x x any and all remaining amount due on the principal upon maturity hereof shall earn interest at the rate of _____ from date of maturity until fully paid." The CA thus properly imposed the legal interest of 12% per annum from the time the loans matured until the same has been fully paid on February 2, 1999. As decreed in Eastern Shipping Lines, Inc. v. Court of Appeals,[12] "in the absence of stipulation, the rate of interest shall be 12% per annum to be computed from default."
	GR No. 159636 2004-11-25	VICTORY LINER v. ROSALITO GAMMAD YNARES-SATIAGO, J.
Finally, in Eastern Shipping Lines, Inc. v. Court of Appeals,[56] it was held that when an obligation, regardless of its source, i.e., law, contracts, quasi-contracts, delicts or quasi-delicts is breached, the contravenor can be held liable for payment of interest in the concept of actual and compensatory damages, subject to the following rules, to wit
	GR No. 148318 2004-11-22	NATIONAL POWER CORPORATION v. ROSE MARIE ALONZO-LEGASTO TINGA, J,
In this case, the omission of the award of interest was obviously inadvertent. Correction is therefore in order. However, we do not agree with the Arbitration Board that the interest should be computed at 12%. Since the case does not involve a loan or forbearance of money, goods or credit and court judgments thereon, the interest due shall be computed at 6% per annum computed from the time the claim was made in 1992 as determined by the Arbitration Board and in accordance with Articles 2209 and 1169 of the Civil Code. The actual base for the computation of legal interest shall be on the amount finally adjudged.[40] Further, when the judgment awarding a sum of money becomes final and executory, the rate of legal interest shall be 12% per annum from such finality until its satisfaction, this interim period being deemed to be by then an equivalent to a forbearance of credit.[41]
	GR No. 158495 2004-10-21	ELIZABETH EUSEBIO-CALDERON v. PEOPLE YNARES-SATIAGO, J.
However, while there can be no stipulated interest, there can be legal interest pursuant to Article 2209 of the Civil Code.[18] It is elementary that in the absence of a stipulation as to interest, the loan due will now earn interest at the legal rate of 12% per annum.[19] In the case of Eastern Shipping Lines, Inc. v. Court of Appeals,[20] we established the guidelines particularly for the award of interest in the concept of actual and compensatory damages, the rate of interest, as well as the accrual thereof as follows:When the obligation is breached, and it consists in the payment of a sum of money, i.e., a loan or forbearance of money, the interest due should be that which may have been stipulated in writing. Furthermore, the interest due shall itself earn legal interest from the time it is judicially demanded. In the absence of stipulation, the rate of interest shall be 12% per annum to be computed from default, i.e., from judicial or extrajudicial demand under and subject to the provisions of Article 1169 of the Civil Code. (Emphasis supplied)
	GR No. 139629 2004-06-21	SANTIAGO LIGHTERAGE CORPORATION v. CA CARPIO, J.
Legal interest at the annual rate of 6% is due on the amounts the trial court awarded.[25] The 6% annual interest shall begin from 4 May 1992, the date of the decision of the trial court. On finality of this decision, annual interest at 12%, in lieu of 6% annual interest, is due on the amounts the trial court awarded until full payment.
	GR No. 132390 2004-05-21	BPI FAMILY SAVINGS BANK v. FIRST METRO INVESTMENT CORPORATION SANDOVAL-GUTIERREZ, J.
Anent the award of interest, petitioner contends that such award is not in order as it had not been prayed for by respondent in its complaint nor was it an issue agreed upon by the parties during the pre-trial of the case. Nonetheless, the rule is well settled that when the obligation is breached, and it consists in the payment of a sum of money, i.e., a loan or forbearance of money, the interest due should be that which may have been stipulated in writing, as in this case. Furthermore, the interest due shall itself earn legal interest from the time it is judicially demanded.[8] Besides, the matter of how much interest respondent is entitled to falls squarely within the issues framed by the parties in their respective pleadings filed with the court a quo. At any rate, courts may indeed grant the relief warranted by the allegations and proof even if no such specific relief is prayed for if only to conclude a complete and thorough resolution of the issues involved.[9]
	GR No. 141538 2004-03-23	HERMANA R. CEREZO v. DAVID TUAZON CARPIO, J.
True, there is such a remedy under our laws, but there is also a more expeditious way, which is based on the primary and direct responsibility of the defendant under article [2180] of the Civil Code. Our view of the law is more likely to facilitate remedy for civil wrongs, because the procedure indicated by the defendant is wasteful and productive of delay, it being a matter of common knowledge that professional drivers of taxis and other similar public conveyances do not have sufficient means with which to pay damages. Why, then, should the plaintiff be required in all cases to go through this roundabout, unnecessary, and probably useless procedure? In construing the laws, courts have endeavored to shorten and facilitate the pathways of right and justice.[50] Interest at the rate of 6% per annum is due on the amount of damages adjudged by the trial court.[51] The 6% per annum interest shall commence from 30 May 1995, the date of the decision of the trial court. Upon finality of this
	GR No. 143584 2004-03-10	SPS. ANTONIO AND SOLEDAD CONSING v. CA CARPIO, J.
The trial and appellate courts imposed legal interest on the P1,243,325.25 without specifying the legal rate of interest. In Eastern Shipping Lines, Inc. v. Court of Appeals ("Eastern Shipping"),[18] we laid down the following guidelines on the imposition of legal interest: When an obligation, regardless of its source, i.e., law, contracts, quasi-contracts, delicts or quasi-delicts is breached, the contravenor can be held liable for damages. The provisions under Title XVII on "Damages" of the Civil Code govern in determining the measure of recoverable damages.
	GR No. 158382 2004-01-27	MANSUETO CUATON v. REBECCA SALUD YNARES-SATIAGO, J.
The case of Eastern Shipping Lines, Inc. v. Court of Appeals,[17] laid down the following guidelines on the imposition of interest, to wit: When the obligation is breached, and it consists in the payment of a sum of money, i.e., a loan or forbearance of money, the interest due should be that which may have been stipulated in writing. Furthermore, the interest due shall itself earn legal interest from the time it is judicially demanded. In the absence of stipulation, the rate of interest shall be 12% per annum to be computed from default, i.e., from judicial or extrajudicial demand under and subject to the provisions of Article 1169 23 of the Civil Code.
	GR Nos. 114967-68 2004-01-26	PEOPLE v. CRISPIN BILLABER Y MATBANUA TINGA, J,
The rate of six percent (6%) per annum as interest imposed on the actual damages of P18,000.00 awarded to private complainant Durano is also erroneous. As the amount of P18,000.00 given by Durano in consideration of his placement constitutes a loan or forbearance of money, the rate of interest should be twelve percent (12%) per annum in line with this Court's pronouncement in Eastern Shipping Lines, Inc. v. Court of Appeals:[80]
	GR No. 120864 2003-10-08	MANUEL T. DE GUIA v. CA CARPIO, J.
ABEJO made an extrajudicial demand on DE GUIA by sending the 27 November 1983 demand letter. Thus, the rent in arrears should earn interest at 6% per annum from 27 November 1983 until finality of this decision pursuant to Article 2209[30] of the Civil Code. Thereafter, the interest rate is 12% per annum from finality of this decision until full payment.[31]
	GR No. 149420 2003-10-08	SONNY LO v. VS.KJS ECO-FORMWORK SYSTEM PHIL. YNARES-SANTIAGO, J.
WHEREFORE, in view of the foregoing, the Decision of the Court of Appeals dated April 19, 2001 in CA-G.R. CV No. 47713, ordering petitioner to pay respondent the sum of P335,462.14 with legal interest of 6% per annum from January 10, 1991 until fully paid is AFFIRMED with MODIFICATION. Upon finality of this Decision, the rate of legal interest shall be 12% per annum, inasmuch as the obligation shall thereafter become equivalent to a forbearance of credit. [23] The award of attorney's fees is DELETED for lack of evidentiary basis.
	GR No. 135377 2003-10-07	DSR-SENATOR LINES v. FEDERAL PHOENIX ASSURANCE CO. SANDOVAL-GUTIERREZ, J.
We have held that a common carrier's duty to observe the requisite diligence in the shipment of goods lasts from the time the articles are surrendered to or unconditionally placed in the possession of, and received by, the carrier for transportation until delivered to or until the lapse of a reasonable time for their acceptance by the person entitled to receive them. When the goods shipped either are lost or arrive in damaged condition, a presumption arises against the carrier of its failure to observe that diligence, and there need not be an express finding of negligence to hold it liable.[11]
	GR No. 156034 2003-10-01	DELSAN TRANSPORT LINES v. C & A CONSTRUCTION YNARES-SANTIAGO, J.
Considering that petitioner did not assail the damages awarded by the trial court, we find no reason to alter the same. The interest imposed should, however, be modified. In Eastern Shipping Lines, Inc. v. Court of Appeals,[33] it was held that the rate of interest on obligations not constituting a loan or forbearance of money is six percent (6%) per annum. If the purchase price can be established with certainty at the time of the filing of the complaint, the six percent (6%) interest should be computed from the date the complaint was filed until finality of the decision. After the judgment becomes final and executory until the obligation is satisfied, the amount due shall earn interest at 12% per year, the interim period being deemed equivalent to a forbearance of credit.[34]
	GR No. 143826 2003-08-28	HEIRS OF IGNACIA AGUILAR-REYES v. SPS. CIPRIANO MIJARES AND FLORENTINA MIJARES YNARES-SANTIAGO, J.
The trial court, however, erred in imposing 12% interest per annum on the amount due the respondents. In Eastern Shipping Lines, Inc. v. Court of Appeals,[47] it was held that interest on obligations not constituting a loan or forbearance of money is six percent (6%) annually. If the purchase price could be established with certainty at the time of the filing of the complaint, the six percent (6%) interest should be computed from the date the complaint was filed until finality of the decision. In Lui v. Loy,[48] involving a suit for reconveyance and annulment of title filed by the first buyer against the seller and the second buyer, the Court, ruling in favor of the first buyer and annulling the second sale, ordered the seller to refund to the second buyer (who was not a purchaser in good faith) the purchase price of the lots. It was held therein that the 6% interest should be computed from the date of the filing of the complaint by the first buyer. After the judgment becomes final and executory until the obligation is satisfied, the amount due shall earn interest at 12% per year, the interim period being deemed equivalent to a forbearance of credit.[49]
	GR No. 138334 2003-08-25	ESTELA L. CRISOSTOMO v. CA YNARES-SANTIAGO, J.
WHEREFORE, the instant petition is DENIED for lack of merit. The decision of the Court of Appeals in CA-G.R. CV No. 51932 is AFFIRMED. Accordingly, petitioner is ordered to pay respondent the amount of P12,901.00 representing the balance of the price of the British Pageant Package Tour, with legal interest thereon at the rate of 6% per annum, to be computed from the time the counterclaim was filed until the finality of this Decision. After this Decision becomes final and executory, the rate of 12% per annum shall be imposed until the obligation is fully settled, this interim period being deemed to be by then an equivalent to a forbearance of credit.[23]