G.R. No. L-39675 - Escueta vs. Fandialan

Plaintiff Francisco Escueta filed a complaint on July 5, 1968, in the Court of First Instance of Laguna (Civil Case No. SP-756).
The complaint sought damages comprising:

The complaint alleged that on July 2, 1952, defendant Eutiquiano Fandialan inflicted several physical injuries on the plaintiff.
In connection with these injuries, the defendant was charged with the crime of frustrated homicide but was ultimately convicted for slight physical injuries.
The conviction was rendered by the Court of First Instance of Laguna and affirmed by the Court of Appeals on August 31, 1955.

On June 20, 1956, having reserved the right to institute a separate civil action, the plaintiff filed a complaint with the same court to enforce the defendant’s civil liability under Article 100 of the Revised Penal Code.
This initial civil case was dismissed for lack of interest on October 31, 1962, without prejudice but with costs.

The applicable statutory limitation is four years under Article 1146 (1) of the Civil Code, which mandates that actions “upon an injury to the rights of plaintiff” must be instituted within four years.

Plaintiff contended that his cause of action for damages should have accrued on August 31, 1955, when the criminal conviction for slight physical injuries became final, rather than on the date of the infliction of injuries.
Plaintiff further argued that the applicable prescriptive period should be ten years under Article 1144 (3), which provides a ten-year limitation for actions "upon a judgment."
Additionally, the plaintiff argued that the prescriptive period was interrupted by the filing and subsequent dismissal of the first civil case in 1956-1962.

The court noted that despite the plaintiff’s reservation to file a separate suit, his civil action for damages is independent of the criminal proceedings.
The court emphasized that the cause of action accrued on July 2, 1952—the date the physical injuries were inflicted.
The execution of a separate civil action does not alter or suspend the running of the prescription period prescribed by law.

Whether the plaintiff’s cause of action for damages accrued on the date the physical injuries were inflicted (July 2, 1952) or on the date when the criminal conviction became final (August 31, 1955).

Whether the appropriate prescriptive period for the plaintiff’s civil action is four years under Article 1146 (1) of the Civil Code or ten years under Article 1144 (3) which applies to actions based “upon a judgment.”