Case Summary (G.R. No. L-29131)
Factual Background
In Civil Case No. 20520, entitled Price Stabilization Corporation vs. Miguel D. Tecson and Alto Surety and Insurance Co., Inc., the Court of First Instance of Manila rendered judgment on November 14, 1955, adjudging liability against Tecson and the surety company and fixing sums payable, interest, attorney's fees, and indemnity obligations. A copy of that decision was served upon the defendants on November 21, 1955, and no appeal was taken.
Revival Proceeding and Pleadings
On December 21, 1965, NATIONAL MARKETING CORPORATION, as successor in interest to Price Stabilization Corporation, filed Civil Case No. 63701 in the same court to revive the judgment rendered in Civil Case No. 20520. Defendant MIGUEL D. TECSON moved to dismiss the revival complaint on the grounds of lack of jurisdiction over the subject matter and prescription.
Trial Court Disposition
The Court of First Instance issued an order on February 14, 1966, denying the jurisdictional objection because the amount involved was less than PHP 10,000 and the proceedings were a revival of a decision of that same court. The court granted the motion to dismiss, however, on prescription grounds, reasoning that the judgment became final on December 21, 1955 and that the revival action was filed more than ten years thereafter. The trial court applied Art. 13 of the Civil Code and concluded that a year equaled three hundred sixty-five days; because 1960 and 1964 were leap years, the ten-year period measured in 3,650 days expired on December 19, 1965, rendering the December 21, 1965 filing two days late.
Question Presented on Appeal
The Court of Appeals certified to the Supreme Court the single question of law whether an action to revive a judgment under Art. 1144-(3), counted from the date the judgment became final under Art. 1152, is barred by prescription when calculated in the manner adopted by the trial court under Art. 13 of the Civil Code.
Parties' Contentions
NATIONAL MARKETING CORPORATION contended that the ten-year prescriptive period should be computed by calendar years so that ten years from December 21, 1955 expired on December 21, 1965, and that the revival complaint, filed on that date, was timely. MIGUEL D. TECSON maintained that Art. 13 of the Civil Code controls and that a year for purposes of legal computation is three hundred sixty-five days; thus ten such years equals 3,650 days and expired on December 19, 1965, rendering the revival action prescribed.
Legal Analysis by the Court
The Court examined the pertinent Civil Code provisions and historical antecedents. It noted that Art. 1144-(3) prescribes a ten-year period for actions upon a judgment and that Art. 1152 fixes accrual of that right from the time the judgment sought to be revived became final. The Court accepted that the judgment became final on December 21, 1955, by application of Sec. 1, Rule 39 in relation to Sec. 3, Rule 31, Rules of Court. It then considered the meaning of "year" for computation under Art. 13 of the Civil Code, which expressly provides that years are of three hundred sixty-five days.
Precedential and Legislative Context
The Court reviewed related jurisprudence and prior statutory regimes. It recalled that under the Spanish Civil Code interpretation months had been deemed of thirty days unless designated by name, and that Section 13 of the Revised Administrative Code subsequently defined "month" to mean a calendar month. With the adoption of the Civil Code of the Philippines, the Court observed that the legislature had explicitly included "years" and defined them as three hundred sixty-five days in Art. 13, thereby superseding prior approaches. The Court acknowledged contrary views among some members regarding practical realism, but emphasized that the Court could not nullify or ignore an express legislative definition.
Ruling and Disposition
The Supreme Court affirmed the order of
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Case Syllabus (G.R. No. L-29131)
Parties and Procedural Posture
- National Marketing Corporation was plaintiff-appellant and successor to Price Stabilization Corporation in the underlying action.
- Miguel D. Tecson was defendant and defendant-appellee in the revival proceeding.
- Alto Surety & Insurance Co., Inc. was co-defendant in the original judgment.
- The case was certified to the Supreme Court by the Court of Appeals on the ground that only a question of law was involved.
- The judgment under review arose from the Court of First Instance of Manila in Civil Case No. 20520 and the revival suit was docketed as Civil Case No. 63701.
Key Factual Allegations
- The Court of First Instance rendered judgment on November 14, 1955 in Price Stabilization Corporation v. Miguel D. Tecson and Alto Surety & Insurance Co., Inc. ordering joint and several payment and indemnity obligations.
- A copy of that judgment was served on the defendants on November 21, 1955.
- National Marketing Corporation, as successor in interest, filed a complaint for revival of the judgment on December 21, 1965.
- No appeal was taken from the November 14, 1955 judgment and it became final thirty days after notice.
Procedural History
- Miguel D. Tecson moved to dismiss the revival complaint for lack of jurisdiction and prescription.
- The Court of First Instance issued an order dated February 14, 1966 dismissing the complaint insofar as Tecson was concerned on the ground of prescription.
- National Marketing Corporation appealed the order to the Court of Appeals which certified the case to the Supreme Court on March 20, 1969.
- The sole legal question certified was whether the action for revival of a judgment was barred by the statute of limitations.
Issue Presented
- Whether an action for revival of a judgment filed on December 21, 1965 was barred by the ten-year prescriptive period applicable to actions upon judgments.
Statutory Framework
- Article 1144-(3), Civil Code prescribed that an action upon a judgment must be brought within ten years from the time the right of action accrues.
- Article 1152, Civil Code provided that the right of action for revival commences when the judgment sought to be revived has become final.
- Article 13, Civil Code declared that "when the laws speak of years ... it shall be understood that years are of three hundred sixty-five days each."
- Rule 39, Sec. 1 in rel