Patrocinio v. Judge Hector C. Fule

Summary

This Supreme Court case involved the collection of legal interest on a P30,000 reimbursement for land improvements on foreshore land. Following a 1977 Supreme Court decision requiring Julian Santulan to reimburse Antonio Lusin for improvements, the trial court imposed 6% legal interest from 1955. The Supreme Court reversed, holding that Article 2209 of the Civil Code did not apply since the obligation was to avoid unjust enrichment, not a delayed monetary debt. Interest was never demanded during the lengthy proceedings, and the original Supreme Court judgment did not provide for it. Imposing interest would be illegal and unjust, especially since Lusin's heirs had been receiving the fruits of the land while in possession, which the Court considered equivalent to interest.