Heirs of Sofia Quirong v. Development Bank of the Philippines

Summary

The Supreme Court affirmed the dismissal of the Quirong heirs' action for rescission of a contract of sale on grounds of prescription. Sofia Quirong purchased a lot from DBP in 1983 with waiver of warranty against eviction. When a subsequent court judgment in 1992 evicted the heirs from 80% of the property in favor of other co-heirs, they filed for rescission in 1998. The Court held that the action was governed by the four-year prescriptive period under Article 1389 for rescission due to eviction, not the ten-year period for written contracts. Since the prescriptive period ran from January 28, 1993 when the eviction judgment became final, the 1998 action was time-barred. The decision clarifies the distinction between rescission (economic injury-based) and resolution (breach of faith-based) in determining applicable prescriptive periods.