Isidro v. Nissan Motor Philippines, Inc.
REITERATIONFacts
The Antecedents: Petitioner purchased a brand new Nissan Sentra from respondent with an express manufacturer's warranty against hidden defects for 24 months or 50,000 kilometers, whichever came first. Procedural History: Petitioner filed a complaint for breach of warranty on August 31, 1998, two years and nine months after delivery. Respondent moved to dismiss, arguing the action had prescribed under Article 1571 of the Civil Code. Petitioner opposed, stating Article 1571 applies only to implied warranties. The Regional Trial Court (RTC) dismissed the complaint, finding the action prescribed as it was filed beyond the two-year warranty period. Petitioner's motion for reconsideration, arguing for four years for rescission and ten years for specific performance, was denied. The Petition: Petitioner sought certiorari from the Supreme Court, assailing the RTC's dismissal orders.
Issue(s)
Whether petitioner's action for enforcement of the manufacturer's express warranty has prescribed. Whether Article 1571 of the Civil Code applies to express warranties.
Ruling
The Supreme Court affirmed the orders of the RTC, denying the petition for review on certiorari.
Ratio Decidendi
On whether petitioner's action for enforcement of the manufacturer's express warranty has prescribed: The Court held that the petitioner's action had prescribed. The manufacturer's warranty explicitly covered defective parts for a period of twenty-four (24) months or fifty thousand (50,000) kilometers, whichever came first. The case of Engineering & Machinery Corporation vs. Court of Appeals was cited, which states that where there is an express warranty in the contract, the prescriptive period is the one specified in the express warranty, if any. The action to enforce the warranty was filed two and a half years from the date of purchase or delivery of the vehicle, which clearly exceeded the stipulated warranty period. Therefore, the period of the guarantee under the express warranty had expired, rendering the action prescribed. On whether Article 1571 of the Civil Code applies to express warranties: While not explicitly ruled upon as a separate issue, the Court's affirmation of the RTC's dismissal, which was based on the expiration of the express warranty period, implicitly supports the distinction between implied and express warranties. The RTC's initial dismissal was based on the prescription of the action, and the petitioner's argument that Article 1571 applies only to implied warranties was not sustained by the Supreme Court in its affirmation. The Court's reasoning focused on the terms of the express warranty itself as the governing factor for prescription in this case, rather than the general prescriptive periods for rescission or specific performance under the Civil Code.
Main Doctrine
An action to enforce an express warranty is governed by the prescriptive period specified in the express warranty itself. If the action is filed beyond the period stipulated in the express warranty, it has prescribed.