G.R. No. 143866 & G.R. No. 143877; May 19, 2006
Poliand Industrial Limited, Petitioner, vs. National Development Company, et al., Respondents.
(Consolidated Cases)
FACTS
The Supreme Court promulgated a consolidated Decision on August 22, 2005, modifying a Court of Appeals ruling. It held National Development Company (NDC) liable to Poliand Industrial Limited for a specified sum, with 12% interest per annum computed from September 25, 1991. Both parties filed motions for partial reconsideration. Poliand argued interest should run from September 12, 1984 (the date of a foreclosure sale). The Court denied these motions in a Resolution dated November 23, 2005. This Resolution, however, modified the August 2005 Decision sua sponte by ruling that interest should instead be computed only from the date of finality of judgment. Poliand then filed a “Second Motion for Partial Reconsideration,” seeking reinstatement of the August 2005 Decision’s reckoning date (September 25, 1991) as an alternative prayer.
ISSUE
Whether Poliand’s subsequent motion is a prohibited second motion for reconsideration, and if not, from what date should the 12% interest on NDC’s liability be computed.
RULING
The Court granted Poliand’s motion. The filing was not a prohibited second motion for reconsideration of the August 2005 Decision. Instead, it sought review of the new ruling on interest computation first introduced in the November 2005 Resolution. To avoid further delay, the Court re-examined the factual basis for computing interest. The trial court’s unmodified finding showed Poliand made an extrajudicial demand on NDC for a specific, liquidated amount on September 25, 1991. A claim is liquidated when the amount due is certain or readily ascertainable. Since the amount was determined and demanded on that date, Poliand’s claim became due and demandable as of September 25, 1991. Therefore, the legal interest should be computed from that date, not from the finality of judgment. Poliand’s primary argument for reckoning from the 1984 foreclosure sale was correctly rejected, as bad faith in foreclosure does not govern interest computation, and the cited maritime law provision (P.D. 1521, Sec. 17) pertains to lien priorities, not interest payment. The dispositive portion of the August 22, 2005 Decision was reinstated in full.
