How to Compute Post-Judgment Interest in Philippine Courts

Post-judgment interest is the interest that accrues on a money judgment from the time the judgment becomes final and executory until it is fully satisfied. It compensates the winning party for the delay in payment after finality, and it also gives the losing party a predictable, mechanical rate to apply while the judgment is being enforced.

Below is a practitioner-style guide to everything you need to know to compute it correctly in the Philippines, with doctrinal anchors, rates, timelines, and worked examples.

1) Legal foundations

Civil Code
- Art. 2209 – If an obligation consists in the payment of a sum of money and the debtor incurs delay, damages shall be the payment of interest.
- Art. 2212 – Interest due shall itself earn legal interest from the time it is judicially demanded (i.e., from filing of the complaint), although courts apply this carefully (see §3 for pre-judgment vs. post-judgment).
- Art. 2213 – No interest on unliquidated claims or damages until they are established with reasonable certainty (typically by judgment).
Key jurisprudence
- Eastern Shipping Lines, Inc. v. CA (1994) – Laid the early framework distinguishing loans/forbearance vs. other money claims.
- Nacar v. Gallery Frames (2013) – The controlling modern doctrine. It (i) reduced the legal interest rate to 6% per annum pursuant to BSP Circular No. 799 (effective 1 July 2013), and (ii) systematized when and what rate applies before and after finality of judgment.
- Numerous later cases apply Nacar’s template; unless a special statute says otherwise, courts follow Nacar for rate and timing.
Bangko Sentral ng Pilipinas (BSP) Circulars
- BSP Circular No. 799 (2013) – Sets the legal interest rate at 6% per annum, superseding the previous 12% under CB Circular 905.
- Post-Nacar, post-judgment interest is 6% per annum across the board on money judgments, starting from finality until full payment.

2) What exactly is “post-judgment interest”?

It is simple interest at 6% p.a. applied to the entire monetary award (principal plus any pre-judgment interest that the judgment has already fixed) starting on the date the judgment becomes final and executory and running until actual satisfaction.
It is compensatory for delay after finality, not punitive.
It applies even if the judgment is silent about post-judgment interest; courts consider it implied by law under Nacar.

3) Don’t confuse it with pre-judgment interest

Pre-judgment interest (before finality) depends on the nature of the claim:
1. Loan or forbearance of money
  - Up to 30 June 2013: 12% p.a.
  - From 1 July 2013 onward: 6% p.a.
2. Other money claims (damages, unpaid price in non-loan contracts, etc.)
  - Courts generally award 6% p.a. from either (a) judicial demand (filing of complaint) if the amount was reasonably ascertainable, or (b) date of judgment when the amount only became certain then.
Post-judgment interest is a separate layer: once the judgment becomes final, the entire adjudged amount earns 6% p.a. regardless of the earlier rate.

4) The 4 dates you must pin down

Accrual/Default date – when delay began (often demand or due date) → relevant to pre-judgment interest.
Cut-over date (1 July 2013) – determines whether any part of pre-judgment period used 12% (pre-799) or 6% (post-799).
Date of judgment – when the court fixed the amount (sometimes the start of pre-judgment interest for unliquidated claims).
Date of finality – starting gun for post-judgment 6% p.a., running until full satisfaction.

Tip: In practice, the Date of Finality is either (a) the date stamped on the Entry of Judgment or (b) the lapse of the reglementary period to appeal when no appeal was filed. Use the date the judgment actually attained finality.

5) The computation framework (step-by-step)

Step A — Determine the adjudged principal and any pre-judgment interest

Compute pre-judgment interest by sub-periods:
- Up to 30 Jun 2013: apply 12% p.a. (only when the pre-judgment period goes back that far and the claim is of the type that earns pre-judgment interest during that span).
- From 1 Jul 2013 to day before finality: apply 6% p.a.
Result: Judgment Amount at Finality (JAF) = Principal + Pre-Judgment Interest awarded + any other monetary components (e.g., attorney’s fees, liquidated damages) if the judgment says they earn interest pre-finality.

Step B — Apply post-judgment interest at 6% p.a. from finality to payment

Use simple interest (no compounding absent a clear stipulation or explicit court directive).
Daily accrual convention: annual rate / 365 × number of days. (Courts accept either day-count or straight year fractions; day-count is cleaner.)
Post-Judgment Interest (PJI) = JAF × 6% × (number of days / 365).

Step C — Partial payments

Credit payments first to interest, then to principal unless the judgment states another allocation.
After each payment, recompute post-judgment interest on the reduced outstanding balance from the date after payment to the next payment or satisfaction.

Step D — Multiple components

If the judgment itemizes different awards with different accrual dates (e.g., actual damages, moral damages, attorney’s fees), compute each item’s pre-judgment interest as directed by the court, sum them to get JAF, then apply one 6% post-judgment to the total from finality.

6) Worked examples

Example 1 — Straightforward monetary award

Principal adjudged: ₱1,000,000
Judgment date: 15 May 2021
Finality: 30 June 2021 (no appeal)
Payment: 15 December 2022 (lump sum)

Assume the court awarded no pre-judgment interest (or it’s already included in the ₱1,000,000).

JAF = ₱1,000,000
PJI period: 30 Jun 2021 → 15 Dec 2022
- Day count = 533 days
- PJI = 1,000,000 × 0.06 × (533/365) = ₱87,726.03
Total due on 15 Dec 2022 = ₱1,087,726.03

Example 2 — With pre-judgment interest and partial payment

Principal: ₱2,000,000
Nature: forbearance of money (loan)
Default: 1 Jan 2012
Judgment date: 1 Oct 2019
Finality: 1 Nov 2019
Partial payment: ₱500,000 on 1 Feb 2021
Full satisfaction: 1 Feb 2022

Pre-judgment:

1 Jan 2012 → 30 Jun 2013 (546 days) at 12%: ₱2,000,000 × 0.12 × (546/365) = ₱359,178.08
1 Jul 2013 → 31 Oct 2019 (2,314 days) at 6%: ₱2,000,000 × 0.06 × (2,314/365) = ₱761,753.42
JAF at finality (1 Nov 2019): ₱2,000,000 + ₱359,178.08 + ₱761,753.42 = ₱3,120,931.50

Post-judgment @6%:

1 Nov 2019 → 1 Feb 2021 (458 days): PJI₁ = 3,120,931.50 × 0.06 × (458/365) = ₱235,202.77 Amount due before payment: ₱3,356,134.27 Apply ₱500,000 payment → Interest first (₱235,202.77), remainder to principal (₱264,797.23). New outstanding principal = 3,120,931.50 − 264,797.23 = ₱2,856,134.27
2 Feb 2021 → 1 Feb 2022 (365 days): PJI₂ = 2,856,134.27 × 0.06 × (365/365) = ₱171,368.06
Final amount to pay on 1 Feb 2022: ₱2,856,134.27 + ₱171,368.06 = ₱3,027,502.33

7) Special issues & edge cases

Judgment silent on interest: Post-judgment 6% still applies by operation of law from finality until payment.
Interest on interest (Art. 2212): Courts can allow interest to earn interest from judicial demand, but this is still simple interest unless compounding is expressly stipulated or commanded by the court. Avoid compounding by default.
Attorney’s fees, moral/exemplary damages: Whether they earn pre-judgment interest depends on the judgment’s wording and whether amounts were liquidated/ascertainable. Post-judgment 6% applies once final.
Foreign currency awards: Philippine courts may respect forex stipulations, but payment/enforcement is typically in PHP equivalent at the time of payment, with post-judgment 6% calculated on the peso-converted amount unless the judgment fixes another basis.
Statutory exceptions: If a special law fixes an interest scheme (e.g., in certain tax, labor, or banking contexts), follow that statute; otherwise default to Nacar.
Multiple defendants / solidary liability: Compute one pot (unless judgment apportions). Payment by one solidary debtor reduces the common obligation; interest then accrues only on the reduced balance.
Stays pending appeal / supersedeas bonds: Unless a statute or court order stays accrual, post-judgment interest continues after finality; a bond doesn’t stop the clock—payment does.
Writs and garnishments: Levy/auction does not itself stop accrual; only actual satisfaction (or deposit with the court in full satisfaction) does.

8) Practical checklist (use this every time)

Extract from the dispositive:
- Principal sums awarded
- Express interest rulings (rates, bases, dates)
- Awarded fees/damages that also earn interest
Build a timeline of: demand/default → filing → judgment → finality → payments.
Compute pre-judgment by sub-periods (12% pre-7/1/2013 where applicable; 6% thereafter).
Sum to get JAF.
Apply 6% p.a. from finality to payment(s); allocate partial payments interest-first.
Document your math (dates, day counts, formulas) in the sheriff’s computation or motion for execution.

9) Boilerplate language you can use

For a draft order/writ: “Pursuant to Nacar v. Gallery Frames and BSP Circular No. 799, the monetary award shall earn legal interest at six percent (6%) per annum from the date the judgment became final and executory until full satisfaction.”
For a computation sheet header: “Post-judgment interest computed at 6% per annum (simple interest) from [Date of Finality] to [Date of Payment], day-count basis (days/365). Partial payments applied first to accrued interest, then to principal.”

10) Quick FAQ

Is post-judgment interest always 6%? Yes, under current doctrine, 6% p.a. from finality until full payment, unless a specific statute/court directive provides otherwise.
Do I compound the interest? No—use simple interest unless compounding is expressly stipulated or ordered.
What if the judgment already included pre-judgment interest? Add it to the principal to form the JAF, then apply 6% p.a. post-judgment to that total.
What stops the clock? Actual full satisfaction (or court-accepted deposit that legally satisfies the judgment). Levies or bonds don’t.

Bottom line

To compute post-judgment interest in Philippine cases: (1) fix the total adjudged amount at finality, including any pre-judgment interest; (2) apply 6% simple interest per annum from finality until full satisfaction; (3) track payments and re-run the math. Do this meticulously and your execution figures will stand up in court.