- Statute
- Civil Code
- Article
- Art. 1144
- Topic
- Prescription of Actions
- Status
- In force
- Book
- BOOK III DIFFERENT MODES OF ACQUIRING OWNERSHIP Preliminary Provision
- Title
- TITLE V PRESCRIPTION
- Chapter
- CHAPTER 3 Prescription of Actions
- Year
- 1949
- Cited by
- Multiple Supreme Court decisions
The provision
The following actions must be brought within ten years from the time the right of action accrues: (1) Upon a written contract; (2) Upon an obligation created by law; (3) Upon a judgment. (n)
Intellegal Wiki · In plain terms
Actions upon a written contract, an obligation created by law, or a judgment must be filed within ten years from when the right of action accrues. Miss the window and the action is barred. It is the default long prescriptive period for these three sources of obligation.
An editorially maintained plain-language explanation of this provision — not legal advice.
Intellegal Wiki · How the courts apply it
In Vector Shipping Corporation v. American Home Assurance Company, the Supreme Court held: The Court held that an insurer's subrogation claim is an obligation created by law with a ten-year prescriptive period under Article 1144(2). This rule was later abandoned in Henson v. UCPB (G.R. 223134, 2019): a subrogated insurer's claim now prescribes with the underlying obligation — four years for a quasi-delict (Art. 1146). Henson applies prospectively, with transitional guidelines for cases filed under the old rule.
One leading Supreme Court case applying this provision.
Cases applying this article
- Anq Construction Corporation v. Ultra Petronne Interior Supply Corporation
- Vicelet Lalicon v. National Housing Authority
- Unlad Resources Development Corporation v. Renato P. Dragon
- Dan Fue Leung v. Hon. Intermediate Appellate Court
- Filcon Ready Mixed v. Ucpb General Insurance Company
- Maxima P. Saclolo v. Romeo Marquito
- Thelma C. Muller v. Philippine National Bank
- Marcelino S. Andrino v. Top Services
Other Supreme Court decisions also apply this article.