Short answer. Yes. Article 2030 of the Civil Code provides that a civil action shall be suspended if it appears that one of the parties, before the case began, offered to discuss a possible compromise but the other party refused. That pre-suit refusal is expressly listed as a ground for suspension once the action is filed.
What the law says
Every civil action or proceeding shall be suspended: (1) If willingness to discuss a possible compromise is expressed by one or both parties; or (2) If it appears that one of the parties, before the commencement of the action or proceeding, offered to discuss a possible compromise but the other party refused the offer
Civil Code, Article 2030 — Suspension for Compromise. Read the full provision →
What the law says
The duration and terms of the suspension of the civil action or proceeding and similar matters shall be governed by such provisions of the rules of court as the Supreme Court shall promulgate
Civil Code, Article 2030 — Suspension for Compromise. Read the full provision →
What Article 2030 provides
Article 2030 of the Civil Code lists two separate triggers for suspending a civil action: "Every civil action or proceeding shall be suspended: (1) If willingness to discuss a possible compromise is expressed by one or both parties; or (2) If it appears that one of the parties, before the commencement of the action or proceeding, offered to discuss a possible compromise but the other party refused the offer." Your situation is the second ground — a refused pre-suit offer, not a current willingness to talk.
Why the refused offer still counts
The second ground does not require that both sides want to negotiate now — it looks back at what happened before the case was filed. If one party "offered to discuss a possible compromise but the other party refused the offer" before the action began, that refusal is itself the fact that triggers suspension, once suit is filed. The rejection does not defeat the ground; it is built into it. Nothing in the text requires the offer to have been accepted, or even seriously considered, for it to count.
How the mechanics of the suspension are worked out
Article 2030 does not itself spell out how long the suspension lasts or exactly how it is carried out. It defers that to procedure: "the duration and terms of the suspension of the civil action or proceeding and similar matters shall be governed by such provisions of the rules of court as the Supreme Court shall promulgate." So the trigger for suspension comes from this article, but the practical details of how it is administered in a given case come from the applicable procedural rules, not from this provision itself.
What this means for your case
Because your pre-suit offer to settle was refused, that refusal fits the exact ground Article 2030 describes for suspending your civil action once it is filed. The suspension is not a courtesy the other side can simply decline a second time — the article ties it to the fact that an offer was made and refused before the case began, not to whether either side wants to keep talking now.
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.
- Alfonso T. Yuchengco, et al. vs. The Honorable Sandiganbayan, et al, G.R. No. 149802, January 20, 2006 — read the decision on LawPhil →
- Rizal Commercial Banking Corporation vs. Magulin Marketing Corporation, et al, G.R. No. 152878, May 5, 2003 — read the decision on LawPhil →