Title
Philippine National Bank vs. Monroy
Case
G.R. No. L-19374
Decision Date
Jun 30, 1964
PNB sought to revive a 1949 judgment against Monroy for unpaid debt. Trial court dismissed, citing prescription. SC reversed, ruling prescription defense waived due to default, and prescriptive period starts from judgment's finality, not rendering.
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Case Summary (G.R. No. L-19374)

Prescription of Action to Enforce Judgment

  • The ten-year period for prescription of an action to enforce a judgment in a civil case begins from the date the judgment becomes final, not from the date it was rendered.
  • This principle is crucial in determining the validity of actions taken to revive or enforce judgments after a significant period has elapsed.

Background of the Case

  • The Philippine National Bank filed a complaint in March 1961 seeking to revive a judgment from May 1949, which required Jose F. Monroy to pay P12,000.00 with interest and attorney's fees.
  • Monroy did not file an answer to the complaint and was subsequently defaulted by the court.
  • The Bank presented evidence of the judgment and Monroy's non-payment, but the court dismissed the action, ruling that the claim had prescribed due to the lapse of more than ten years since the judgment was rendered.

Appeal and Legal Arguments

  • The Bank appealed the dismissal, arguing that prescription is a defense that Monroy waived by not answering the complaint, and thus the court should not have applied it sua sponte.
  • Monroy did not respond to this argument, as he had not received a copy of the Bank's brief due to his default in the lower court.
  • The issue of whether the court could decide on the prescription based solely on the dates in the complaint was not necessary to resolve, as the judge made a legal error in concluding that the action had prescribed.

Legal Conclusion and Judgment

  • The court determined that the ten-year prescription period should be counted from when the judgment became final, not from when it was rendered.
  • Since the complaint did not specify the date when the judgment became final, the court erred in declaring the action prescribed.
  • Consequently, the court ordered Monroy to pa...continue reading

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