Gliceria Marella v. Agripino Agoncillo

Summary

Plaintiffs sought to collect P10,032.42 debt owed by deceased Felisa Arriola from business transactions and money lending arrangements dating back to her father's dealings with plaintiff Gliceria Marella. The Court of First Instance denied the claim on grounds that the action had prescribed. The Supreme Court reversed, holding that since the cause of action accrued in 1899 before the Code of Civil Procedure took effect, Civil Code prescription rules applied. Under the Civil Code, personal actions prescribe in 15 years, but prescription was interrupted by extrajudicial demands made between 1906-1910. Since the complaint was filed in 1913, the prescription period had not elapsed. The decision established important precedent regarding the application of prescription rules when causes of action arose before procedural code changes, and the effect of extrajudicial demands in interrupting prescription periods under the Civil Code.