Philippine Bank of Communications v. Diamond Seafoods Corporation

Summary

PBCom sued Diamond Seafoods Corporation and individual sureties for collection of money based on defaulted trust receipts totaling P327,844.03. The obligations matured in March and May 1983, but the civil complaint was filed only in July 1993, approximately 10 years later. All three court levels dismissed the case on prescription grounds under Article 1144 of the Civil Code, which provides a 10-year period for actions based on written contracts. The Supreme Court clarified that Article 1155 of the Civil Code, not Act No. 3326, governed interruption of prescription in civil cases, but found no valid interruption occurred since demand letters were never received by defendants and the criminal complaint filing did not constitute effective demand. The case establishes that prescription periods for civil actions cannot be interrupted by ineffective demands or criminal complaints where defendants are not properly notified.