- Petitioner
- Patrocinio Yu
- Respondent
- Hon. Court of Appeals
- Citation
- G.R. No. 106818
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Vitug, J.
- Decided
- May 27, 1994
Summary
Patrocinio Yu, owner of a drugstore, obtained loans from Traders Royal Bank secured by various instruments including trust receipts executed in 1980. When Yu defaulted, TRB filed multiple cases for collection. Yu subsequently filed a case in 1988 seeking nullity of the trust receipts, claiming he signed documents without full understanding. The Supreme Court affirmed the dismissal of Yu's case, ruling that while litis pendentia did not strictly apply due to substantial differences between the cases, Yu's action had prescribed. The Court determined that Yu's cause of action was based on fraud or mistake in the execution of trust receipts, which under Civil Code Article 1391 prescribes in four years. Since the trust receipts were executed in 1980 and the case was filed in December 1988, the four-year prescriptive period had elapsed. The decision clarifies the requirements for litis pendentia and emphasizes the importance of timely filing actions for annulment of contracts based on defective consent.