G.R. No. 72645 - Luzon Surety Co., Inc. vs. Intermediate Appellate Court

In Civil Case No. 59506 before the Court of First Instance of Manila, a judgment was rendered against the defendants, including Gil Puyat, for the principal sum of P20,000.00 with interest at 12% per annum, compounded quarterly from June 25, 1958, in addition to P3,608.00 for premiums and stamps.
The judgment became final on April 13, 1967, but it was never enforced.

Within the prescribed period, Civil Case No. 93268 was instituted to revive the original judgment rendered in Civil Case No. 59506.
On May 24, 1974, a judgment was rendered in Civil Case No. 93268 ordering the defendants to pay the plaintiff the same principal sum, with interest computed from June 25, 1958, plus unpaid premiums, stamps, and costs of suit.
The revived judgment also provided for reimbursement on the crossclaim against Material Distributors (Phil.), Inc. and Lope Sarreal to Gil J. Puyat for potential liabilities.

Gil Puyat died on March 28, 1981.
On September 1, 1982, a claim amounting to P178,507.76 (inclusive of interests, unpaid premiums and stamps, attorney’s fees, and court costs) was filed against his estate in Special Proceedings No. Q-32291 before the Court of First Instance of Rizal.
The Administrators opposed the claim on the ground that it was unenforceable and barred by laches, emphasizing that no steps were taken to secure a writ of execution against Gil Puyat during his lifetime.
On November 8, 1983, the Regional Trial Court of Quezon City, Branch LXXXVIII, issued a judgment dismissing the claim.

The petitioner, Luzon Surety Company, Inc., appealed the dismissal, but the then Intermediate Appellate Court (now the Court of Appeals) affirmed the lower court’s ruling.
The appellate court highlighted that the period for enforcement of a judgment under Section 6 of Rule 39 is five years, after which the judgment may only be enforced by action within a ten-year prescriptive period starting from the finality of the original judgment.
Since more than ten years had elapsed from the finality of the original judgment (April 13, 1967) by the time the claim was instituted (September 1, 1982), the petitioner's right to enforce the judgment had already prescribed.

Whether the ten-year prescriptive period under Article 1144(3) of the New Civil Code should be computed from the finality of the original judgment (Civil Case No. 59506) or from the finality of the revived judgment (Civil Case No. 93268).

Whether the five-year period provided for executing a judgment by motion impacts the computation of the overall ten-year limitation period for enforcement.

Whether the claim filed in Special Proceedings No. Q-32291 is enforceable given that the right to enforce the original judgment had purportedly prescribed.

Whether the reasoning in Philippine National Bank v. Bondoc (which suggests a new cause of action upon revival) or in Philippine National Bank v. Deloso (which upholds that the prescriptive period runs from the finality of the original judgment) controls the determination in this case.