DONABELLE GONZALES-SALDANA v. SPS.

AUTHOR: Reyes, Brixton

NIAMATALI
G.R. No. 226587 November 21, 2018
TOPIC: Actual or Compensatory Damages
PONENTE: J. Reyes Jr.
CASE LAW/ DOCTRINE:
As a form of damages, compensatory interest is due only if the obligor is proven to have failed to comply with
his obligation. 6% per annum is the rate of interest applicable in transactions involving the payment of
indemnities in the concept of damages arising from the breach or a delay in the performance of obligations in
general.
Emergency Recit:
Sps. Gordon and Amy Niamatali (Respondents) sought to buy a real property in Las Pinas so they remitted
P3,000,000.00 to Donabelle Gonzales-Saldana (Petitioner) to participate in the DOLE Sheriff’s public auction
an purchase it. However, Petitioner instead purchased real properties in Paranaque and Manila with the
money without approval of Respondents. Respondents did not want to purchase the said properties and
demanded the return of the P3,000,000.00 to no avail. The SC ruled in favor of Respondents due to her failure
to comply with the principal obligation of purchasing the Las Pinas property. Furthermore, the CA award of
compensatory interest of six percent (6%) per annum was approved by the SC because of Petitioner’s breach
of said obligation.

FACTS:
1. In January 2002, respondent-spouses Gordon and Amy Niamatali (Respondents), then residing in the
United States of America, informed DOLE employee Donabelle Gonzales-Saldana (Petitioner) of their
intention to acquire real properties in Metro Manila. Respondent informed them that a certain parcel
of land located in Las Pifias City would be sold in a public auction conducted by the DOLE Sheriff's
Office.

2. Respondents asked Petitioner to participate in the public auction and remitted US$60,000.00 or
P3,000,000.00 for purchase of the property. However, Petitioner informed them that the auction did
not push through because of a third-party claim.

3. Despite this, the judgment creditor agreed to sell the Paranaque and Manila properties which were
also levied on execution to Petitioner. Petitioner bought them without approval of the Respondents.

4. When Respondents returned to the country in July 2002, petitioner brought respondent-spouses to
the Las Pinas property but it was locked up and a signboard was posted, on which the words "Future
Home of Lutheran School and Community Center" were written so they informed Petitioner that they
were no longer interested in acquiring the Las Pinas property and asked for the return of the
P3,000,000.00, to which petitioner agreed.

5. Despite several demands from Respondents, Petitioner failed to return the P3,000,000.00 to them.
She told them that she would return their money but she had to sell first the Manila and Paranaque
properties so they filed a collection suit against her.

6. RTC: Ruled in Petitioner’s favor.

7. CA: Reversed RTC Decision. It ordered Petitioner to pay P3,000,000.00 with interest at six percent
(6%) per annum.

ISSUE(S): Whether Petitioner should return the P3,000,000.00 she received from Respondents for the
purchase of the Las Pifias property and the payment of interest on the amount due.
HELD: Yes. Petitioner, as an implied agent to Respondents, should return the amount and is liable for
payment of compensatory interest.
RATIO:
MONETARY INTEREST
- Interest is a compensation fixed by the parties for the use or forbearance of money. Article 1956 of
the Civil Code, which refers to monetary interest, specifically mandates that no interest shall be due
unless it has been expressly stipulated in writing.
COMPENSATORY INTEREST
- Interest that may also be imposed by law or by courts as penalty or indemnity for damages. As a
form of damages, compensatory interest is due only if the obligor is proven to have failed to
comply with his obligation.

In this case, Petitioner's principal obligation was to purchase the Las Pinas property for Respondents.
Consequently, when she was informed that the auction sale of the Las Pifias property would have to be
cancelled, Petitioner should have simply returned the P3,000,000.00 to Respondents instead of purchasing
the Manila and Parafiaque properties without the latter's knowledge and consent.

The obligation to return the money is a consequence of her failure to comply with her principal obligation,
The breach entitles Respondents to the payment of interest at the rate of 6% per annum is the rate of interest
applicable in transactions involving the payment of indemnities in the concept of damages arising from the
breach or a delay in the performance of obligations in general as held in Eastern Shipping Lines, Inc. v. Court of
Appeals.