Short answer. From the time the judgment became final. Article 1152 states that the prescriptive period for demanding fulfillment of an obligation declared by a judgment commences from that finality date, not from when the judgment was first rendered or from when enforcement efforts actually began.
What the law says
The period for prescription of actions to demand the fulfillment of obligation declared by a judgment commences from the time the judgment became final.
Civil Code, Article 1152 — Actions Upon a Judgment. Read the full provision →
Finality, not rendition, is the starting point
Article 1152 fixes a precise trigger for this kind of prescription. The period for prescription of actions to demand the fulfillment of obligation declared by a judgment commences from the time the judgment became final. The relevant date is when the judgment became final — meaning it is no longer subject to appeal or the period to appeal has lapsed — not the earlier date the court first handed down its decision.
Why the distinction between rendition and finality matters
A judgment can be rendered and still be actively contested through a pending appeal or motion, during which its obligation has not yet become truly enforceable in a settled way. Article 1152 accounts for this by tying the start of the prescriptive period to finality rather than to the original rendition, so a judgment still working its way through appellate review does not start a clock running on an obligation that might still be modified or reversed.
This governs actions to demand fulfillment, specifically
The article is written for actions to demand the fulfillment of obligation declared by a judgment — meaning it addresses the situation where a party already has a judgment in hand and is asking a court to enforce or compel performance of what that judgment already established. This is distinct from prescription rules governing the original underlying claim before any judgment existed; once a judgment is obtained, this article's finality-based rule takes over for the fresh period tied to that judgment itself.
What this means for enforcing your judgment
If you are trying to work out how much time you have left to pursue enforcement, the date that matters is when your judgment actually became final, not the date it was first issued or the date you decided to act on it. Confirming the finality date — accounting for whether an appeal was taken and when it was resolved, if at all — is the necessary first step before you can determine where you stand within the prescriptive period this article establishes.
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.
- Edgardo A. Quilo and Adnaloy Villahermosa vs. Teodula Bajao, G.R. No. 186199, September 7, 2016 — read the decision on LawPhil →
- Rufa A. Rubio, et al. vs. Lourdes Alabata, G.R. No. 203947, February 26, 2014 — read the decision on LawPhil →
- Ernesto Villeza vs. German Management and Services, Inc., et al, G.R. No. 182937, August 8, 2010 — read the decision on LawPhil →
- Lucila David and the Heirs of Rene F. Aguas, namely: Princess Luren D. Aguas, G.R. No. 241036, January 26, 2021 — read the decision on LawPhil →