National Marketing Corporation v. Tecson
REITERATIONFacts
The Antecedents: On November 14, 1955, the Court of First Instance of Manila rendered a judgment in Civil Case No. 20520, ordering defendants Miguel D. Tecson and Alto Surety and Insurance Co., Inc. to pay PRATRA P7,200.00 plus interest, attorney's fees, and costs. Defendant Tecson was also ordered to indemnify his co-defendant Alto Surety for any amount paid to the plaintiff. Procedural History: Copy of the decision was served on November 21, 1955. On December 21, 1965, the National Marketing Corporation (NAMARCO), as successor to PRATRA, filed a complaint (Civil Case No. 63701) to revive the judgment. Defendant Tecson moved to dismiss, citing lack of jurisdiction and prescription. The trial court dismissed the complaint against Tecson, ruling that while jurisdiction was not an issue, the action had prescribed because it was filed two days late, considering that 1960 and 1964 were leap years and Article 13 of the Civil Code defines a year as 365 days. The Appeal: The National Marketing Corporation appealed the dismissal order to the Court of Appeals, which certified the case to the Supreme Court, as the sole issue was the interpretation of the prescriptive period for reviving a judgment.
Issue(s)
Whether the action for revival of judgment filed on December 21, 1965, was barred by the statute of limitations, considering that the judgment became final on December 21, 1955, and the years 1960 and 1964 were leap years. Whether a 'year' for the purpose of computing the prescriptive period under the Civil Code refers to a calendar year or a period of 365 days.
Ruling
The Supreme Court affirmed the order of dismissal. The action for revival of judgment was found to have prescribed.
Ratio Decidendi
On Issue 1: The Court held that the action for revival of judgment was barred by the statute of limitations. Article 1144(3) of the Civil Code mandates that an action upon a judgment must be brought within ten (10) years from the time the right of action accrues, which is when the judgment becomes final. The judgment in question became final on December 21, 1955. Therefore, the ten-year period expired on December 21, 1965. However, the appellee argued, and the lower court agreed, that due to the inclusion of leap years (1960 and 1964), the ten-year period, computed at 365 days per year as per Article 13 of the Civil Code, actually expired on December 19, 1965. The complaint was filed on December 21, 1965, making it two days late. On Issue 2: The Court definitively ruled that for the purpose of computing prescriptive periods under Philippine law, a 'year' is understood to be 365 days, as explicitly stated in Article 13 of the Civil Code. This provision was a modification from the Spanish Civil Code, which previously had different interpretations regarding months and days. The Court rejected the appellant's argument that a 'year' should be interpreted as a calendar year, which would include the extra day in a leap year. The Court emphasized that it cannot disregard or nullify a clear statutory provision, such as Article 13, and engage in judicial legislation by reviving the policy of Section 13 of the Revised Administrative Code, which defined a month as a calendar month. The Court stressed that any change in this policy must come from the legislature.
Main Doctrine
The Supreme Court affirmed the dismissal of an action for revival of judgment due to prescription, holding that the ten-year prescriptive period under Article 1144(3) of the Civil Code was exceeded. The Court strictly applied Article 13 of the Civil Code, which defines a 'year' as 365 days, thus excluding the extra day in leap years from the computation of the prescriptive period. The Court emphasized that adherence to statutory definitions is paramount, and courts cannot deviate from legislative intent even if the rule seems impractical.