Romeo T. Saavedra v. Rosario Punzalan

Summary

This case involves the prescription of the right to execute a final judgment in a mortgage foreclosure case. Romeo Saavedra obtained a favorable Court of Appeals decision in 2001 ordering foreclosure of Primo Eustaquio's property, which became final on February 19, 2003. Despite obtaining a writ of execution in 2004, Saavedra failed to conduct the auction sale and only filed a motion for public auction on September 9, 2013—over ten years after the judgment became final. The Supreme Court affirmed the lower courts' ruling that Saavedra's right to execute the judgment had prescribed under the five-year period for motions and ten-year period for actions prescribed by the Rules of Court and Civil Code. The Court rejected Saavedra's excuses about delayed discovery of the heirs' addresses, emphasizing that as a lawyer, he should have known about prescription periods and acted with due diligence.