- Petitioner
- Philippine National
- Respondent
- Dionisio
- Citation
- G.R. No. L-18342
- Court
- Supreme Court
- Decided
- September 19, 1963
Summary
Philippine National Bank sought to revive a 1949 money judgment against the Dionisios for unpaid loans. The bank argued that extrajudicial demands sent in 1954 interrupted the prescriptive period. Both the trial court and Supreme Court disagreed, holding that under the applicable law (Act No. 190), written extrajudicial demands do not interrupt the prescriptive period for enforcing final judgments. The Court applied the old law rather than the New Civil Code due to transitional provisions, since prescription began running before the new code took effect. This case establishes that extrajudicial demands cannot indefinitely extend the period for enforcing final judgments, ensuring finality in judicial proceedings and preventing indefinite revival of old judgments through mere demands.
Intellegal Wiki · Key Holding
Affirmed the dismissal, holding that because the money judgment became final before the New Civil Code took effect, the transitional provision (Article 1116) made the old law (Act No. 190) control, under which written extrajudicial demands do not interrupt the prescriptive period, so the action to revive the judgment had prescribed.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.