Enrique F. Somes v. Wife

Summary

This 1905 Supreme Court case involved interpretation of prescription periods under the Civil Code for collection of a promissory note. Ignacio Gorricho borrowed 200 pesos from Manuel F. Somes in 1891, promising monthly payments that were never made. When Somes' heir sued in 1903, defendants claimed the 5-year prescription under Article 1966(3) applied. The Supreme Court held that promissory notes with fixed payment dates fall under the general 15-year prescription for personal obligations under Article 1964, not the 5-year period for recurring payments. The Court distinguished between contractually-fixed payment dates and recurring payment obligations, establishing important precedent for debt collection prescription periods.