Petitioner
Philippine National
Respondent
Court of Appeals
Citation
G.R. No. L-27117
Court
Supreme Court
Decided
July 30, 1969

Summary

The Supreme Court ruled that partial payment of a debt does not interrupt the prescriptive period for reviving a judgment under Article 1155 of the Civil Code. The Court emphasized that the Civil Code requires 'written' acknowledgment to interrupt prescription, unlike the old Spanish Civil Code. PNB's attempt to revive a 1953 judgment in 1964 based on Cornejo's P150 partial payment in 1956 failed because the payment, evidenced only by a creditor's receipt, did not constitute written acknowledgment by the debtor. The decision clarifies that actions to revive judgments prescribe from when they become final, and partial payments without written acknowledgment cannot toll this period. This affirmed the Court of Appeals' reversal of the trial court's pro-PNB decision.

Statutes applied

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By the Intellegal Editorial Board · July 30, 1969

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