Luzon Surety Company v. Intermediate Appellate Court

Summary

Luzon Surety Company obtained a judgment against Gil Puyat in 1967, which it revived in 1974. After Puyat's death in 1981, the company filed a claim against his estate in 1982 seeking to enforce the revived judgment. The estate opposed the claim as time-barred. The core legal issue was whether the 10-year prescriptive period for enforcing judgments under Article 1144(3) of the Civil Code runs from the original judgment's finality or from the revived judgment's finality. The Supreme Court affirmed the lower courts' dismissal, ruling that prescription runs from the original judgment's finality in 1967, making the 1982 claim filed more than 15 years later time-barred. The decision clarified that reviving a judgment does not reset the prescriptive period, following the Philippine National Bank v. Deloso precedent over the earlier conflicting Bondoc ruling.