G.R. No. 164401 ; June 25, 2008
Lilibeth Sunga-Chan and Cecilia Sunga, petitioners, vs. The Honorable Court of Appeals; The Honorable Presiding Judge, Regional Trial Court, Branch 11, Sindangan, Zamboanga Del Norte; The Regional Trial Court Sheriff, Branch 11, Sindangan, Zamboanga Del Norte; The Clerk of Court of Manila, as Ex-Officio Sheriff; and Lamberto T. Chua, respondents.

FACTS

Respondent Lamberto T. Chua and Jacinto Sunga formed a partnership in 1977, operating under the name Shellite Gas Appliance Center, registered as a sole proprietorship under Jacinto. After Jacinto’s death in 1989, petitioners Cecilia Sunga (widow) and Lilibeth Sunga-Chan (daughter) continued the business without Chua’s consent. Chua filed a complaint for winding up of partnership affairs, accounting, and recovery of shares. The RTC ruled in favor of Chua, a decision affirmed with finality by the Supreme Court in G.R. No. 143340 . The RTC decision ordered petitioners to render an accounting, return partnership assets, and pay Chua his share, including earned but unreceived income from 1988 to 1992.
During execution, the RTC, due to petitioners’ failure to submit a proper accounting, approved Chua’s computation of his claims amounting to PhP 8,733,644.75, which included the principal sum and interest. Petitioners challenged this via certiorari before the CA, arguing the RTC committed grave abuse of discretion in approving Chua’s computation, particularly the imposition of interest on unliquidated claims. The CA denied the petition, prompting this appeal.

ISSUE

Whether the Court of Appeals erred in upholding the Regional Trial Court’s approval of the computation of claims which included interest on unliquidated sums.

RULING

The Supreme Court denied the petition and affirmed the CA. The legal logic centers on the nature of the claims and the applicable interest. The Court distinguished between liquidated and unliquidated claims. A liquidated claim is one whose amount is determined or readily determinable. The RTC’s 1997 decision, which became final, ordered petitioners to pay Chua “earned but unreceived income and profits from the partnership from 1988 to May 30, 1992… the sum of P35,000.00 per month.” This specific monetary award constituted a liquidated sum. Therefore, interest thereon was mandatory pursuant to Article 2209 of the Civil Code from the time of judicial demand, which was the filing of the complaint in 1992.
The Court clarified that the interest imposed was not on an unliquidated claim for damages but on a liquidated sum adjudged by final judgment. The compounding of interest in Chua’s initial computation was correctly rejected by the RTC. The approved computation using simple interest was proper. The RTC did not commit grave abuse of discretion; it performed its duty to execute a final judgment. Its approval of the computation, after petitioners’ failure to comply with the accounting order, was a logical step to give effect to the executory decision. The CA correctly found no jurisdictional error warranting certiorari.