Araneta v. Garrido
REITERATIONFacts
The Antecedents: The plaintiff-appellee, Miguel Piccio Araneta, initiated a personal action for the recovery of money against the defendant-appellant, Jose Garrido. The cause of action in this case accrued on January 1, 1884. Procedural History: The case was decided in the court below. Subsequently, it was brought before the Supreme Court on appeal. The Appeal: Both parties argued the case before the Supreme Court based on the theory that it should be governed by the provisions of the Civil Code concerning the prescription of actions. The appellant contested the judgment rendered by the lower court.
Issue(s)
Whether the prescription of the action for recovery of money is governed by the Civil Code or by the laws in force prior to its promulgation. Whether the action was filed within the applicable prescriptive period.
Ruling
The Supreme Court affirmed the judgment of the lower court. It held that the applicable law for determining the prescription of the action is the legislation in force prior to the promulgation of the Civil Code, as the prescription commenced to run before the Civil Code took effect. The Court found that the action was filed within the twenty-year prescriptive period established by the prior laws.
Ratio Decidendi
On Issue 1: The Supreme Court held that the prescription of the action for recovery of money is governed by the laws in force prior to the promulgation of the Civil Code. This is because the cause of action accrued on January 1, 1884, which was before the Civil Code took effect on December 8, 1889. The Court cited Article 1939 of the Civil Code, which states that prescription that began to run before the publication of the code shall be governed by the prior laws. Furthermore, Section 38 of the Code of Civil Procedure, which took effect on September 1, 1901, explicitly states that it shall not apply to actions where the right of action has already accrued, and the statutes in force when the action or right of action accrued shall be applicable. The Court noted that the ten-year period mentioned in the proviso of Section 38 had not elapsed when the action was commenced. On Issue 2: The Supreme Court determined that the action was filed within the applicable prescriptive period. According to the legislation in force prior to the Civil Code, personal actions prescribed after twenty years, as provided by Law 63 of Toro and Law 5, Title 8, Book 11, of the Novisima Recopilacion. The action was commenced on April 22, 1903. Since the cause of action accrued on January 1, 1884, the twenty-year prescriptive period had not yet elapsed at the time the action was filed. Therefore, the action was not barred by prescription.
Main Doctrine
The Supreme Court affirmed that the prescriptive period for actions is determined by the law in effect at the time the cause of action accrued. In this case, the cause of action accrued in 1884, prior to the effectivity of the Civil Code. Therefore, the prescriptive period was governed by the laws in force before the Civil Code, which stipulated a twenty-year period for personal actions, not the fifteen-year period under the Civil Code or the ten-year period under the Code of Civil Procedure's proviso. The Court found that the action, commenced in 1903, was filed within the twenty-year prescriptive period.