Petitioner
Tarcisio S. Calilung
Respondent
Paramount Insurance Corporation
Citation
G.R. No. 195641
Court
Supreme Court
Division
First Division
Ponente
Bersamin, J.
Decided
July 11, 2016

Summary

This case involves a dispute over compounded interest during the execution phase of a final and executory judgment. Petitioner Calilung sought compounded interest on a judgment debt of P718,750 with 14% per annum interest, arguing Article 2212 of the Civil Code and Eastern Shipping doctrine applied. The RTC initially flip-flopped on the issue through three orders. The Supreme Court ultimately denied the petition, holding that compounded interest cannot be imposed during execution since the final judgment did not decree such compounding. The Court emphasized that execution must strictly conform to the final decree and cannot vary therefrom, as allowing compounded interest would violate the doctrine of immutability of judgments. The decision clarifies the distinction between monetary and compensatory interest and reinforces that post-judgment modifications violating immutability principles are prohibited.

Statutes applied

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By the Intellegal Editorial Board · July 11, 2016

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