Short answer. No. Article 1217 says that if payment of a solidary debt is made before the debt is due, no interest for the intervening period may be demanded. You can recover each co-debtor's share, but not interest for the time between your early payment and the original due date.
What the law says
If the payment is made before the debt is due, no interest for the intervening period may be demanded.
Civil Code, Article 1217 — Payment by a Solidary Debtor; Reimbursement. Read the full provision →
You can recover shares, but not early-period interest
When one solidary debtor pays, the whole debt is extinguished and that payer gains a right of reimbursement against the others. Article 1217 says he may claim from his co-debtors only the share which corresponds to each, with the interest for the payment already made. But it then draws a firm line for early payers: If the payment is made before the debt is due, no interest for the intervening period may be demanded. So you are entitled to collect each co-debtor's proportional share, yet you cannot add interest for the stretch of time between your premature payment and the date the debt would actually have fallen due.
Why the early period earns no interest
The rule is fair to your co-debtors. The term of the obligation — the time before it was due — benefited all of you; none of you was obliged to pay yet. By choosing to pay ahead of schedule, you gave up that benefit on your own initiative. The law will not let you convert your voluntary decision into an extra cost for the others by charging them interest for a period during which they were entitled to hold their money. Your co-debtors did not ask you to accelerate, so they should not have to fund the time value of an early payment they never requested.
What you can still claim
The bar is limited to interest for the intervening period; it does not wipe out your reimbursement. You remain entitled to each co-debtor's share of what you paid. And the article separately provides for insolvency: When one of the solidary debtors cannot, because of his insolvency, reimburse his share to the debtor paying the obligation, such share shall be borne by all his co-debtors, in proportion to the debt of each. So if one co-debtor cannot pay you back, his portion is spread among the rest — including you — rather than falling on you alone. Your core right to be made whole for the shares survives.
Practical takeaway
Before paying a solidary debt ahead of its due date, weigh that you will carry the cost of that early period yourself. If preserving a claim to interest matters to you, waiting until the debt matures — or agreeing in advance with your co-debtors about an early settlement — avoids the loss the article imposes. When you do collect, keep your claim to each person's share and, where relevant, invoke the insolvency-sharing rule, but do not expect interest for the time you jumped ahead of the schedule everyone was entitled to enjoy.
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.
- Benigno M. Vigilla, Alfonso M. Bognot, et al. vs. Philippine College of Criminology, Inc. and/or Gregory Alan F. Bautista, G.R. No. 200094, June 10, 2013 — read the decision on LawPhil →
- Gloria Paje, Lolita Gomez, Miriam Catacutan, Estrella Zapata, Gloria Sumang, Juanita Julieta Dingal, Myra Amante, and Fe S. Bernardo vs. Spic N' Span Service Corporation, G.R. No. 240810, February 28, 2022 — read the decision on LawPhil →
- Republic Glass Corporation, et al. vs. Lawrence C. Qua, G.R. No. 144413, July 30, 2004 — read the decision on LawPhil →
- Rafael M. Crisol, Jr. vs. Commission on Audit, G.R. No. 235764, September 14, 2021 — read the decision on LawPhil →