Meridian Assurance Corporation v. Hon. Abelardo M. Dayrit

Summary

Supreme Court granted certiorari petition challenging trial court's application of 12% interest rate under Central Bank Circular No. 416 to monetary judgment. The Court ruled that the 12% rate applies only to judgments involving loans or forbearance of money, goods or credits, not all monetary judgments. Following precedents in Reformina v. Tomol Jr. and Philippine Rabbit Bus Lines v. Cruz, the Court held that 6% interest under Civil Code Article 2209 was proper. The Court annulled trial court orders and declared petitioner's deposit of P170,061.03 representing principal debt, 6% interest, and costs as full satisfaction of the judgment, establishing important precedent on interest rate application in commercial judgment enforcement.