Short answer. No. Under Article 13 of the Civil Code, in computing a period the first day is excluded and the last day is included. So if you receive a decision today and have fifteen days to act, you start counting from tomorrow as day one, and the deadline falls on the fifteenth day after today.
What the law says
In computing a period, the first day shall be excluded, and the last day included.
Civil Code, Article 13 — Computation of Periods. Read the full provision →
What the law says
When the laws speak of years, months, days or nights, it shall be understood that years are of three hundred sixty-five days each; months, of thirty days; days, of twenty-four hours; and nights from sunset to sunrise.
Civil Code, Article 13 — Computation of Periods. Read the full provision →
Exclude the first day, include the last
Article 13 of the Civil Code ends with the rule that decides most deadline questions: In computing a period, the first day shall be excluded, and the last day included. The day the period starts running — the day you were served the decision, signed the contract, or received the demand — is day zero, not day one. Counting begins with the following day. The last day of the period, on the other hand, is a full working day for whatever the deadline requires: an act done on that final day is still on time. So a fifteen-day period that starts running on the 1st of the month runs from the 2nd and ends on the 16th, not the 15th.
Why the first day does not count
The logic is fairness in fractions. On the day an event happens — service of a judgment at 4 p.m., say — part of the day is already gone, and counting it as a full day would quietly shorten every period by however many hours had passed before the event. Article 13 avoids that by treating days as units of twenty-four hours and starting the count only when a complete day is available. The same article standardizes the other time words the law uses: years are understood as three hundred sixty-five days, months as thirty days unless a month is designated by name, and nights run from sunset to sunrise. Those definitions matter when a period is stated in months or years rather than days.
A worked example
Suppose you receive an adverse decision on March 3 and the law gives you fifteen days to seek reconsideration. March 3 is excluded. Day one is March 4, day two is March 5, and so on, which makes day fifteen March 18 — the last day included. You may file on March 18 itself and still be within the period. What you cannot safely do is treat March 3 as day one and assume the period ends March 17, because although that mistake lands you a day early rather than a day late, the same confusion running the other way — treating the deadline as one day later than it is — is exactly how rights are lost. Count it once, the statutory way, and mark the final date.
What this article does not settle
Article 13 supplies the general rule, but specific deadline problems often carry extra layers it does not answer. Procedural rules and special laws can have their own computation provisions for filings in court or with agencies, including how to treat a final day that falls on a weekend or holiday, and those specific rules govern within their own sphere. The safest practice for anything that matters — an appeal, a redemption, a prescriptive period — is to compute the deadline the strict Article 13 way, then confirm against the specific rule that governs your filing, and never plan to act on the last possible day if you can avoid it. When real money or a case is riding on the count, have a lawyer verify the date.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Mitsubishi Motors Philippines Corporation vs. Chrysler Philippines Labor Union, et al, G.R. No. 148738, June 29, 2004 — read the decision on LawPhil →
- Ma. Zarah Rose De Guzman Lara vs. Commission on Elections and Manuel N. Mamba, G.R. No. 265847, August 6, 2024 — read the decision on LawPhil →
- Commissioner Internal Revenue vs. Aichi Forging Company of Asia, Inc, G.R. No. 184823, October 6, 2010 — read the decision on LawPhil →
- Commissioner of Internal Revenue, et al. vs. Primetown Property Group Inc, G.R. No. 162155, August 28, 2007 — read the decision on LawPhil →