G.R. No. L-1700
FACTS:
Plaintiff Miguel Piccio Araneta filed a personal action for the recovery of money against defendant Jose Garrido. The cause of action accrued on January 1, 1884, but the action was only commenced on April 22, 1903. Both parties in the lower court proceeded on the theory that the case was governed by the prescription rules of the Civil Code.
ISSUE:
Which law governs the prescription of the actionthe laws in force prior to the Civil Code or the Civil Code itselfconsidering that the right of action accrued before the Civil Code took effect?
RULING:
The Supreme Court ruled that the prescriptive period is governed by the laws in force prior to the promulgation of the Civil Code, as the prescription began to run on January 1, 1884, before the Civil Code took effect on December 8, 1889. Under the prior laws (specifically Law 63 of Toro and the Novísima Recopilación), personal actions prescribed in twenty (20) years. Since the action was filed in 1903, less than twenty years had elapsed from the accrual of the cause of action in 1884. Therefore, the action had not yet prescribed. The Court affirmed the judgment of the lower court.