Teodoro S. Benedicto v. Julian Perizuelo

Summary

This case involved the collection of an acknowledged debt by an estate administrator against a debtor who raised prescription as a defense. Julian Perizuelo had acknowledged owing 4,559.05 pesos Mexican to Teodoro Benedicto in a written document dated September 30, 1894, with 15% annual interest. After Benedicto's death, his estate administrator sued to collect the debt, which had grown to P10,164.01 with accumulated interest. The defendant argued prescription, claiming it was an action for rent subject to a 5-year limitation period. The Supreme Court clarified this was a personal action to recover an acknowledged debt, subject to the 15-year prescription period under Article 1964 of the Civil Code. Since the limitation period had not expired, the action was not time-barred. The decision established important precedent distinguishing between actions for rent versus personal actions for debt collection in determining applicable prescription periods.