Herminia Cando v. Sps. Aurora Olazo

Summary

This case involves a mortgage foreclosure dispute where the trial court erroneously dismissed the complaint for prescription, computing the 10-year period from the mortgage contract date rather than from default. The Court of Appeals dismissed the appeal for lack of jurisdiction, finding it raised pure questions of law. The Supreme Court reversed, clarifying that Article 1142's 10-year prescriptive period for mortgage actions runs from when the right of action accrues (upon mortgagor's default), not from the mortgage contract date. The Court emphasized that procedural rules should promote substantial justice and applied liberal interpretation to prevent injustice caused by the trial court's legal error. This decision is significant for establishing the proper computation of prescription periods in mortgage foreclosure cases and demonstrating the Court's willingness to overlook procedural lapses to prevent manifest injustice.