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	GR No. 200567 2015-06-22	METROPOLITAN BANK v. CPR PROMOTIONS VELASCO JR., J.
Similarly, in Bank of the Philippine Islands, Inc. v. Spouses Norman and Angelina Yu,[66] the Court reduced the claim for attorney's fees from 10% to 1% based on the following reasons: (1) attorney's fee is not essential to the cost of borrowing, but a mere incident of collection; (2) 1% is just and adequate because the mortgagee bank had already charged foreclosure expenses; (3) attorney's fee of 10% of the total amount due is onerous considering the rote effort that goes into extrajudicial foreclosures.
	GR No. 194781 2012-06-27	RGM INDUSTRIES v. UNITED PACIFIC CAPITAL CORPORATION REYES, J.
However, pursuant to Bank of the Philippine Islands, Inc. v. Yu,[13] we deem it proper to further reduce the penalty charge decreed by the CA from 2% per month to 1% per month or 12% per annum in view of the following factors: (1) respondent has already received P7,504,522.27 in penalty charges, and (2) the loan extended to respondent was a short-term credit facility.