Procesa Pelaez v. Flaviano Abreu

Summary

This landmark 1913 case established important precedent regarding prescription of actions in contractual disputes. Pelaez sold property to Abreu under pacto de retro with rental arrangements, later seeking recovery of P863.81 representing rents collected by defendant that should have been credited to redemption price. The Supreme Court's reversal turned on statutory interpretation, holding that Article 1973 of the Civil Code (allowing verbal demands to interrupt prescription) was repealed by Section 50 of the Code of Civil Procedure, which requires written acknowledgments. The decision demonstrates the Court's strict construction of prescription periods and the legislative intent to make the Code of Civil Procedure the complete law on prescription of civil actions, increasing the rigorousness of prescription requirements for creditors.