- Petitioner
- Carlos B. de Guzman
- Respondent
- Toyota Cubao
- Citation
- G.R. No. 141480
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Azcuna, J.
- Decided
- November 29, 2006
Summary
Carlos De Guzman purchased a Toyota Hi-Lux from Toyota Cubao, Inc. in November 1997. When the engine cracked in October 1998, he demanded replacement based on implied warranty, which respondent refused. De Guzman filed a complaint for damages in April 1999. The RTC dismissed the case, ruling that the six-month prescriptive period under Civil Code Article 1571 for warranty actions had expired. The Supreme Court denied De Guzman's petition, first on procedural grounds for violating the hierarchy of courts by not appealing to the Court of Appeals, and second on the merits, confirming that his action based on implied warranty against hidden defects was time-barred. The case establishes that actions for breach of implied warranty must be filed within six months of delivery under Article 1571, and even under consumer protection law, the prescribed periods had lapsed.