Alfredo Cabral v. Court of Appeals

Summary

This case involves a land sale where buyers discovered they could not possess the property as promised due to prior occupation and area deficiency. The Supreme Court addressed whether appellate courts can award interest on refund amounts when trial courts did not award interest and appellees did not appeal. The Court held that under Article 2210 of the Civil Code, courts have discretion to award interest on damages for breach of contract. Since the Free Patent sale was void ab initio (disposed within the 5-year prohibition), defendants had no title to the purchase money and must refund it with interest. The Court adopted a liberal stance allowing appellate relief not originally sought, but corrected the interest rate from 12% to 6% per annum, as 12% applies only to loans or forbearance, not contract breach damages. The decision emphasizes deciding cases on merits rather than technicalities while maintaining proper legal interest rates.