National Marketing Corp. vs. Tecson

Under Article 13 of the Civil Code, a "year" for legal purposes consists of exactly 365 days; consequently, when computing multi-year prescriptive periods, each intervening leap day must be excluded, and the period expires correspondingly earlier than the calendar anniversary date.

The case originated from Civil Case No. 20520 of the Court of First Instance (CFI) of Manila, wherein Price Stabilization Corporation (PRATRA) obtained a money judgment against Miguel D. Tecson and Alto Surety & Insurance Co., Inc. National Marketing Corporation later acquired all properties, assets, and choses in action of PRATRA, including the judgment credit.

• November 14, 1955: CFI Manila rendered judgment in Civil Case No. 20520 (Price Stabilization Corporation v. Miguel D. Tecson and Alto Surety and Insurance Co., Inc.).
• November 21, 1955: Copy of decision served upon defendants.
• December 21, 1955: Judgment became final (30 days from notice, no appeal taken).
• December 21, 1965: National Marketing Corporation filed Civil Case No. 63701 (RTC Manila) for revival of the 1955 judgment.
• February 14, 1966: RTC issued order dismissing the complaint for prescription (filed two days late due to leap years).
• March 20, 1969: Court of Appeals certified the case to the SC, finding only a question of law was involved.
• August 27, 1969: SC affirmed the dismissal.

• Nature of Action: Action for revival of judgment under Article 1144(3) of the Civil Code.
• Parties: National Marketing Corporation (successor-in-interest of Price Stabilization Corp., plaintiff-appellant) v. Miguel D. Tecson (defendant-appellee).
• November 14, 1955: CFI Manila rendered judgment ordering Tecson and Alto Surety to pay PRATRA P7,200.00 plus 7% interest and P500.00 attorney's fees.
• November 21, 1955: Decision served on defendants.
• December 21, 1955: Judgment became final (30 days elapsed without appeal).
• December 21, 1965: National Marketing Corporation filed complaint for revival of judgment (exactly 10 calendar years later).
• Tecson's Defense: Filed motion to dismiss on grounds of lack of jurisdiction and prescription, arguing that under Article 13, Civil Code, the 10-year period expired on December 19, 1965, because 1960 and 1964 were leap years.
• RTC Ruling: Granted motion to dismiss, holding that 10 years of 365 days each (3,650 days) from December 21, 1955 expired on December 19, 1965, making the December 21 filing two days late.

• A "year" should be interpreted as a "calendar year" (citing Crawford on Statutory Construction).
• December 21 to December 21 of the following year constitutes one full year, regardless of leap years.
• The extra day in a leap year (the 366th day) must necessarily belong to that year, meaning a leap year is still "one year."
• Therefore, filing on December 21, 1965 was exactly 10 years from December 21, 1955 and was timely.

• Article 13 of the Civil Code explicitly provides: "when the laws speak of years... it shall be understood that years are of three hundred sixty-five days each."
• 1960 and 1964 were leap years (February had 29 days).
• Computing 10 years of exactly 365 days each (3,650 days) from December 21, 1955, the period expired on December 19, 1965.
• The action filed on December 21, 1965 was barred by the 10-year prescriptive period under Article 1144(3) of the Civil Code.

• Procedural Issues: Whether the Court of Appeals properly certified the case to the SC. (Alternatively: N/A — certification was procedural but unchallenged).
• Substantive Issues: Whether the action for revival of judgment filed on December 21, 1965 was barred by prescription, considering that Article 13 of the Civil Code defines a year as 365 days and 1960 and 1964 were leap years.

• Procedural: The CA properly certified the case to the SC pursuant to Section 4 of Republic Act No. 296, as the appeal raised only a pure question of law (the interpretation of Article 13 of the Civil Code).
• Substantive: The action was barred by prescription. Article 13 of the Civil Code explicitly limits the connotation of each "year" to 365 days. The 10-year period under Article 1144(3) commenced on December 21, 1955. Computing 3,650 days (10 years × 365 days) from that date, and accounting for the two extra days in the leap years 1960 and 1964, the period expired on December 19, 1965. The filing on December 21, 1965 was therefore two days too late. The "calendar year" theory would require judicial legislation and nullification of Article 13.

• Article 13, Civil Code (Fixed Computation of Time) — Establishes that years are 365 days and months are 30 days for legal purposes. The SC applied this strictly: a "year" is a fixed 365-day period, not a calendar year that varies between 365 and 366 days. Leap year days are excluded from the count.
• Article 1144(3) and Article 1152, Civil Code — Govern the 10-year prescriptive period for actions upon judgments and provide that the right of action accrues from the time the judgment becomes final.
• Prohibition on Judicial Legislation — Courts cannot modify clear statutory provisions under the guise of interpretation, even if the provision seems unrealistic or inconvenient; amendment must come from the legislature.

• "when the laws speak of years... it shall be understood that years are of three hundred sixty-five days each" — Article 13, Civil Code.
• "The very conclusion thus reached by appellant shows that its theory contravenes the explicit provision of Art. 13 of the Civil Code of the Philippines, limiting the connotation of each 'year' - as the term is used in our laws - to 365 days."
• "If public interest demands a reversion to the policy embodied in the Revised Administrative Code [which defined 'month' as calendar month], this may be done through legislative process, not by judicial decree."

• People v. Del Rosario — Cited to establish that the Civil Code of the Philippines reverted to the Spanish Civil Code concept of fixed 30-day months and explicitly added the definition of a year as 365 days.
• Guzman v. Lichauco and Gutierrez v. Carpio — Cited regarding the superseded Section 13 of the Revised Administrative Code, which had defined "month" as a calendar month, contrasting with the Civil Code's fixed-day approach.

• Article 13, Civil Code — "When the laws speak of years... it shall be understood that years are of three hundred sixty-five days each."
• Article 1144(3), Civil Code — 10-year prescriptive period for actions upon judgments.
• Article 1152, Civil Code — Prescriptive period commences from the time the judgment sought to be revived has become final.
• Section 13, Revised Administrative Code — (Contrasted) Previously defined "month" as calendar month; superseded by Civil Code Article 13 regarding months and years.

N/A (Justices Concepcion, Dizon, Makalintal, Sanchez, Castro, Fernando, Capistrano, Teehankee, and Barredo concurred; Justices Reyes and Zaldivar were on official leave abroad).