Jesus T. David v. The Court of Appeals

Summary

Jesus David sought to execute a 1979 RTC judgment ordering Valentin Afable Jr. to pay P66,500.00 plus legal interest from 1966. During execution, David claimed compound interest should apply under Article 2212 of the Civil Code, computing the total as P3,027,238.50, while the sheriff applied simple interest totaling P270,940.52. The Supreme Court denied David's petition, holding that Article 2212 applies only when parties stipulated conventional interest which has accrued at the time of judicial demand. Since no interest was stipulated in their compromise agreement, and the judgment awarded only simple legal interest without mentioning compound interest, execution must conform to the judgment's dispositive portion. The Court applied the Philippine American Accident Insurance precedent and affirmed that only simple interest should be computed, recognizing that CB Circular No. 416 was a supervening event that properly modified interest rates during the execution phase.