G.R. No. 114299 & No. 118862; March 9, 2000
Traders Royal Bank vs. Court of Appeals, Capay, et al. / Capay, et al. vs. Santos, et al.

FACTS

The consolidated cases originated from a dispute over a parcel of land. The Capays and Ramon Gonzales (movants) were the original owners. Traders Royal Bank (TRB) acquired the property and subsequently sold it to Emelita Santiago, who then sold it to various subsequent transferees. The trial court ruled in favor of the movants, ordering the cancellation of the titles issued to the transferees and awarding moral and exemplary damages, attorney’s fees, and legal interest against TRB. The Court of Appeals initially affirmed this but, upon reconsideration, dismissed the complaint against the subsequent transferees, thereby restoring their titles. However, the appellate court’s decision sustaining the monetary award against TRB remained. The Supreme Court, in its September 29, 1999 Decision, affirmed the Court of Appeals’ rulings and additionally ordered TRB to pay the movants the fair market value of the property at the time of its sale to Santiago.
The movants filed a Motion for Partial Reconsideration. They prayed for the explicit inclusion in the dispositive portion of the Supreme Court’s Decision of the earlier award for moral damages, exemplary damages, and attorney’s fees. They also asked that TRB be ordered to pay them the specific sale price of P47,730.00 (from the TRB-Santiago deed) plus 12% interest per annum from the date of that sale, instead of the fair market value.

ISSUE

The issues for resolution were: (1) whether the Supreme Court’s Decision deleted the award of damages affirmed by the Court of Appeals; and (2) what specific amount and interest rate should be paid by TRB as the value of the lost property.

RULING

The Supreme Court partially granted the motion. On the first issue, it clarified that the award of moral damages, exemplary damages, and attorney’s fees was not deleted. The Court explained that TRB, in its appeal to the Supreme Court, did not specifically question this award of damages. Consequently, the issue was beyond the Court’s review, and the affirmation of the Court of Appeals’ decision necessarily included the sustained monetary awards. The omission of a detailed recital of these damages in the Supreme Court’s dispositive portion was not a deletion, and thus the prayer for their explicit inclusion was denied.
On the second issue, the Court modified its earlier order for payment of fair market value. Applying Article 1400 of the Civil Code, a person obliged to return a lost property must return its value at the time of loss with interest. The movants insisted on the specific price in the deed of sale (P47,730.00), to which TRB posed no objection. The Court treated this as a stipulation on the property’s value. It granted the payment of P47,730.00, with interest at 12% per annum from the date of the sale to Santiago until full payment, the amount being considered a forbearance of credit. The dispositive portion of the September 29, 1999 Decision was amended accordingly.