G.R. No. 254142 , July 27, 2021
Spouses Roque and Fatima Ting, represented by her Attorney-in-Fact, Santiago J. Tanchan, Jr., Petitioners, vs. Commission on Audit and City of Cebu, Respondents.

FACTS

Petitioners Spouses Roque and Fatima Ting entered into a Memorandum of Agreement with the Metro Cebu Development Project III (MCDP III), a project of respondent City of Cebu, for an exchange of lots. MCDP III demolished petitioners’ lots without completing the exchange. Petitioners filed a case for Specific Performance and Damages against the City of Cebu. The Regional Trial Court (RTC) ruled in favor of petitioners, ordering the City to pay Php37,702,500.00 (comprising the value of the lots and demolished structures, plus attorney’s fees and litigation expenses) with interest at 6% per annum from the date of the RTC judgment until fully paid. The City of Cebu appealed. The Court of Appeals denied the appeal, and the Supreme Court denied the City’s subsequent appeal. An Entry of Judgment stated the case became final and executory on March 9, 2015. Petitioners then filed a petition for money claim before the Commission on Audit (COA) for payment of the judgment award. The COA partially granted the petition but modified the reckoning date for the 6% per annum interest, ordering it to be computed from May 23, 2017 (the day after the filing of the money claim), instead of from the RTC judgment date, reasoning that the delay in filing the claim was attributable to petitioners. Petitioners moved for partial reconsideration, which the COA denied.

ISSUE

Whether the Commission on Audit committed grave abuse of discretion by modifying the reckoning date for the computation of legal interest on a final and executory judgment.

RULING

Yes, the Commission on Audit committed grave abuse of discretion. The Supreme Court partly granted the petition. It held that the COA’s power of audit review over money claims confirmed by a final judgment is limited and cannot alter such judgment without violating the principle of immutability of final judgments. Citing Nacar v. Gallery Frames, the Court ruled that the legal interest of 6% per annum on a monetary award runs from the date of finality of the judgment until its satisfaction. The finality date was March 9, 2015, as per the Entry of Judgment, not the RTC decision date (January 3, 2008) claimed by petitioners, nor the date after the money claim filing (May 23, 2017) set by the COA. The COA’s modification of the interest reckoning date had no basis in law or jurisprudence. Therefore, the Supreme Court modified the COA Decision and Resolution, affirming that the City of Cebu is liable to pay petitioners Php37,702,500.00 plus interest at 6% per annum from March 9, 2015, until fully paid.