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