Philippine National Bank… · G.R. 123643

Petitioner: Philippine National Bank
Respondent: Court of Appeals
Citation: G.R. No. 123643
Court: Supreme Court
Division: Third Division
Ponente: Francisco, J.
Decided: October 30, 1996

Summary

The Supreme Court resolved the proper interest rate applicable to monetary judgments in damages cases. PNB challenged the 12% interest rate imposed on unpaid purchase price for medicines, arguing it should be 6%. The Court distinguished between obligations arising from loans/forbearance of money (12% under CB Circular 416) versus contract breaches not involving loans (6% under Article 2209, Civil Code). Applying Eastern Shipping Lines precedent, the Court ruled 6% interest applies from complaint filing until judgment finality, then 12% thereafter as the interim period constitutes forbearance of credit. This clarifies interest computation rules for different types of civil obligations and establishes clear guidelines for future cases.

Statutes applied

Civil Code, Art. 2209

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Government Service Insurance System v. Hon. Court of Appeals G.R. No. 103590
Food Terminal v. Court of Appeals G.R. No. 120097
Philippine Virginia Tobacco Administration v. Hon. Ricardo P. Tensuan G.R. No. 58817
Meridian Assurance Corporation v. Hon. Abelardo M. Dayrit G.R. No. 59154
Reinsurance Company of the Orient v. The Honorable Court of Appeals G.R. No. 61250
Central Azucarera de Bais v. The Honorable Court of Appeals G.R. No. 87597
Antonio L. Castelo v. The Court of Appeals G.R. No. 96372
Pilipinas Bank v. The Hon. Court of Appeals G.R. No. 97873

Other Philippine cases also address these provisions and issues.

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By the Intellegal Editorial Board · October 30, 1996

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