Short answer. Six months from delivery, not from discovery. Article 1571 bars actions on the hidden-defect warranty six months from the delivery of the thing sold, so a fault that only shows itself a year later is already outside the warranty and has to be argued on some other ground.
What the law says
Actions arising from the provisions of the preceding ten articles shall be barred after six months, from the delivery of the thing sold.
Civil Code, Article 1571 — Prescription of Warranty Actions (Six Months). Read the full provision →
The period runs from delivery, whatever you knew
The whole rule is one sentence: Actions arising from the provisions of the preceding ten articles shall be barred after six months, from the delivery of the thing sold. Nothing in it turns on when the buyer found out. That is deliberate and it is harsh, because the point of a hidden defect is precisely that it was not visible at delivery. The law's answer is that a warranty against latent faults cannot hang over a seller indefinitely, so it fixes the outer limit at the one date both sides can prove — the day the thing changed hands.
Which claims the six months actually covers
It covers the block of articles immediately preceding it, beginning with Article 1561 — the warranty that the thing sold is free of hidden defects rendering it unfit for its intended use, together with the buyer's election under Article 1567 to withdraw from the contract or demand a proportionate reduction of the price. If your complaint is that the item is defective, that is the action being barred. Article 1570 applies the same subsection to judicial sales, so buying at auction does not buy you a longer period either.
What the six months does not bar
Missing the period does not always end the matter. If the seller actively concealed the fault or made a false statement that induced you to buy, the complaint is no longer about warranty but about consent, and Article 1391 allows an action for annulment within four years, counted in case of fraud from the discovery of the fraud. A separate written or manufacturer's warranty is a contract in its own right and runs on its own terms. Those are different cases with different proof, and the evidence for them is gathered differently.
Fix the delivery date first
Because everything turns on one date, establish it before you argue anything else. Delivery is not necessarily the day you signed or the day you paid — it is when the thing was placed in your control, and for goods released later than the deed that later date is the one that counts. Find the release or gate pass, the bill of lading, the acceptance receipt, the registration handover. Then count six months forward. If the date has passed, say so to your lawyer at the start rather than after the demand letter has gone out.
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.
- Engineering & Machinery Corp. vs. Court of Appeals, et al, G.R. No. 52267, January 24, 1996 — read the decision on LawPhil →
- Carlos B. De Guzman vs. Toyota Cubao, Inc, G.R. No. 141480, November 29, 2006 — read the decision on LawPhil →
- Spouses Mario and Julia Gaspar vs. Hermino Angel E. Disini, Jr., Joesph Yu, doing, G.R. No. 239644, February 3, 2021 — read the decision on LawPhil →
- National Power Corporation, et al. vs. Court of Appeals, et al, G.R. No. 113103, June 13, 1997 — read the decision on LawPhil →
Related provisions
- Civil Code, Article 1571 — Prescription of Warranty Actions (Six Months)
- Civil Code, Article 1561 — Warranty Against Hidden Defects
- Civil Code, Article 1567 — Buyer's Options for Hidden Defects (Redhibition/Quanti Minoris)
- Civil Code, Article 1391 — Four Years to Annul