Michael Alcantara v. Rustans Supercenters

Summary

This Supreme Court case involves the proper interest rate computation on reimbursement obligations under the solutio indebiti principle. Petitioner Alcantara made amortization payments totaling P569,892.00 to RSI for a car, but RSI could not deliver ownership as they were merely lessees. The Court applied Civil Code Article 2154, requiring RSI to reimburse payments with interest. The key issue was whether 6% or 12% per annum interest applied. The Supreme Court affirmed the 6% rate, holding this was not a loan or forbearance of money but a reimbursement obligation. Following Nacar v. Gallery Frames, the Court applied graduated interest rates: 6% from complaint filing until decision finality, 12% from finality until June 30, 2013, then 6% thereafter. The decision clarifies interest computation guidelines for civil reimbursement obligations and reinforces the prospective application of BSP interest rate changes in civil monetary awards.