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Updated 3rd February 2025
National Marketing Corp. vs. Tecson
The Supreme Court resolved whether an action for the revival of a judgment filed exactly ten calendar years after its finality was barred under the statute of limitations in light of the Civil Code provision defining a "year" as 365 days. The Court affirmed the dismissal of the case, ruling that the ten-year limitation had already lapsed due to the inclusion of leap years, which made the total time span exceed 3,650 days.

Primary Holding

An action to revive a judgment must be filed within ten years or 3,650 days from the date the judgment became final, as defined by Article 13 of the Civil Code. Beyond this period, revival is barred by prescription.

Background

The Price Stabilization Corporation obtained a final judgment in 1955 against Miguel Tecson. Years later, the National Marketing Corporation, as its successor, attempted to revive this judgment in 1965. The trial court dismissed the case, finding that the action was filed beyond the ten-year prescription period. The only issue on appeal was whether the action to revive had prescribed.

History

  • November 21, 1955: Final judgment in Civil Case No. 20520 served.

  • December 21, 1955: Judgment became final, as no appeal was taken.

  • December 21, 1965: National Marketing Corporation filed a complaint to revive the judgment.

  • February 14, 1966: Trial court dismissed the complaint for being filed two days late.

  • March 20, 1969: Court of Appeals certified the case to the Supreme Court due to a pure question of law.

  • August 27, 1969: Supreme Court affirmed the dismissal.

Facts

  • 1. The original judgment ordered Tecson and Alto Surety & Insurance Co. jointly and severally to pay ₱7,200 plus interest, attorney’s fees, and costs.
  • 2. The National Marketing Corporation filed for revival exactly ten calendar years after the judgment became final.
  • 3. Tecson argued that the action was filed two days late when computed in days (3,650 days), given the leap years in the interim.

Arguments of the Petitioners

  • 1. A year should be interpreted as a calendar year (from December 21 to December 21), irrespective of whether leap years altered the number of days.
  • 2. Using 365 days per year would effectively result in a shorter period than ten calendar years.

Arguments of the Respondents

  • 1. Under Article 13 of the Civil Code, a "year" is defined as 365 days. Since two leap years occurred between 1955 and 1965, the ten-year period expired on December 19, 1965 (3,650 days after December 21, 1955).

Issues

  • 1. Should the ten-year prescription period be computed in terms of calendar years or in days (365-day years, accounting for leap years)?
  • 2. Did the filing of the complaint on December 21, 1965, comply with the prescription period?

Ruling

  • 1. The Supreme Court held that the term "year," as defined in Article 13 of the Civil Code, means 365 days. Therefore, the ten-year limitation period expired on December 19, 1965, making the December 21, 1965 filing late.
  • 2. The Court emphasized that judicial interpretation cannot contradict explicit statutory provisions.

Doctrines

  • 1. Article 13 of the Civil Code: Defines a "year" as 365 days, regardless of leap years.
  • 2. Article 1144(3) of the Civil Code: Actions upon a judgment must be brought within ten years from its finality.
  • 3. Article 1152 of the Civil Code: The prescription period starts when the judgment becomes final.

Precedents Cited

  • 1. People v. Del Rosario (97 Phil. 70–71): Interpreted "year" as defined under the Civil Code, reverting to the Spanish Civil Code's concept of months and years.
  • 2. Guzman v. Lichauco, 42 Phil. 292: Defined months and years in similar contexts.
  • 3. Gutierrez v. Carpio, 53 Phil. 334: Clarified the difference between natural and artificial time measures.

Statutory and Constitutional Provisions

  • 1. Civil Code, Article 13: Defines the term "year" as 365 days.
  • 2. Civil Code, Article 1144(3): Prescribes a ten-year limitation for actions upon judgments.
  • 3. Civil Code, Article 1152: States that prescription begins when the judgment becomes final.