31 be calculated under the same formula until payment is actually made, and that the interest rate will be the Libor rate in force in the month of May of each year. 88. Later, in the public hearing the representatives stated that there were several agreements between them and the State, being one of these that an amount should be set in regard to interests, but that there was still a discrepancy regarding the interest rate and the date as of which they should be computed. They requested that the Court establish said standards. In this sense, they reiterated to the Tribunal that “it should define a formula for compound interests as has been done by several arbitration courts in matters of investments.”138 They added that “this is the same principle that should be applied, since even though the matter in dispute is not directly about investments, we cannot deny that it refers to an identical right, namely the right to property.” 89. On its part, at the public hearing the State expressed that on July 16, 1996, the Municipality of the Metropolitan District of Quito filed the complaint before the “Court of Justice”139 in order to obtain the occupation order, and that the Ecuadorian legislation states in these cases, that in order to be able to occupy the property, the just price must be recorded. According to the State, in this case, along with the filing of the complaint for expropriation it recorded the amount of the just price in the Municipality’s opinion at that time at 225,990,625.00 Sucres.140 This means that the municipality has never failed to comply with its obligations, and that regarding the representatives’ current expectation to receive interests, the legal actions set out by the municipality are not being recognized, and they are trying to collect payment of an interest charge that does not correspond. Payment of interests is an additional payment, which results from not honoring an obligation. In this sense, the State provided evidence on the record of that indicated and expressed that it has never wanted to diminish the agreement reached with the opposing party regarding the payment of interests, and it stated its willingness to respect it. 90. Without detriment of the aforementioned, the State mentioned that any estimate of the interests made by the Court should be made as of the year 1997, between the 6th and 10th days of July 1997. Said date was determined by the Court in the Judgment on the Merits as the one on which the Municipality of Quito occupied the property, and not as of May 13, 1991, date of the declaration of public interest, as was requested by the representatives. Additionally, it reiterated that “acknowledging the differential initial amount sought by the victim is alien to the standard of justice.” 91. From that indicated by the representatives and the State at the public hearing, the Court observes that they agree that this Tribunal determine an interest as a consequence of the lack of payment of a just compensation for the expropriated property.141 Therefore, the 138 In this regard, they cited the example of the Judgment rendered by the Centre for Settlement of Investment Disputes (ICSID) in the Compañía del Desarrollo Santa Elena S.A. V. Costa Rica, supra note 92. 139 It is worth mention that in the Judgment of Merits it was established that the expropriation filed by the Metropolitan Municipality of Quito against María and Julio Guillermo Salvador Chiriboga was presented on July 16, 1996. The expropriation trial was listed under No. 1300-96, which was initiated that same day before the Ninth Court. Cf. Case of Salvador Chiriboga V. Ecuador, supra note 24, paras. 4 and 103. 140 In the main documents, the representatives as well as the State, made statements regarding the amount of the payment consigned with the lawsuit of expropriation in the process No. 1300-96. The representatives indicated that the amount of Sucres assigned with the writ of the lawsuit of expropriation corresponded to the date of the presentation of that writ, and the amount of $9.032.00 (nine thousand and thirty two dollars of the United States of America) (written brief containing pleadings, motions, and evidence, file on preliminary objections and merits, Volume II, pp. 145) On the other hand, the State indicated that the value of the amount consigned at the moment of payment, when the lawsuit of expropriation was presented, represented almost US$ 300.000,00 (three hundred thousand dollars of the United States of American) (the States plea, file on preliminary objections and merits, Volume II, page 219) 141 It is important to note that the State in its note of January 13, 2009, stated yet again that there is no liquidation obligation nor is there a default by the Municipality, to which the payment of interest does not follow. It