Short answer. Yes. Article 1231 of the Civil Code expressly says annulment, rescission, fulfillment of a resolutory condition, and prescription are other causes of extinguishment, on top of the six it lists by number. They are simply governed elsewhere in the Code rather than detailed in this particular article.
What the law says
Obligations are extinguished: (1) By payment or performance; (2) By the loss of the thing due; (3) By the condonation or remission of the debt; (4) By the confusion or merger of the rights of creditor and debtor; (5) By compensation; (6) By novation.
Civil Code, Article 1231 — Modes of Extinguishing Obligations. Read the full provision →
What the law says
Other causes of extinguishment of obligations, such as annulment, rescission, fulfillment of a resolutory condition, and prescription, are governed elsewhere in this Code.
Civil Code, Article 1231 — Modes of Extinguishing Obligations. Read the full provision →
The six numbered modes are not the whole list
Article 1231 opens with a numbered list: Obligations are extinguished: (1) By payment or performance; (2) By the loss of the thing due; (3) By the condonation or remission of the debt; (4) By the confusion or merger of the rights of creditor and debtor; (5) By compensation; (6) By novation. Read in isolation, that numbered list looks complete. But the article does not stop there, and the second sentence exists specifically to correct that impression.
The article names rescission and resolutory conditions directly
Article 1231 continues: Other causes of extinguishment of obligations, such as annulment, rescission, fulfillment of a resolutory condition, and prescription, are governed elsewhere in this Code. Both rescission and the fulfillment of a resolutory condition are named explicitly as additional ways an obligation ends. The word such as signals that even this second list is illustrative rather than exhaustive, but rescission and resolutory conditions are not left to inference — the article states them by name.
Why they are not in the numbered list
Article 1231 explains why these causes are mentioned but not detailed here: they are governed elsewhere in this Code. The six numbered modes are the ones this article itself defines and regulates in the provisions that follow it. Rescission, annulment, fulfillment of a resolutory condition, and prescription each have their own set of rules located in other parts of the Code, so Article 1231 only flags that they exist rather than folding their rules into its own numbered list.
Why the distinction is worth knowing
If you are trying to work out whether an obligation has actually ended, checking only the six numbered modes can be misleading, because a rescinded contract or one tied to a resolutory condition that has been fulfilled can extinguish the obligation just as completely, through rules found in other parts of the Code rather than in this article's own list. Article 1231's second sentence is what tells you to keep looking beyond the numbered list before concluding an obligation must still be alive.
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.
- Ruby Shelter Builders vs. Romeo Y. Tan, G.R. No. 217368, August 5, 2024 — read the decision on LawPhil →
- Sheriff Albert A. Dela Cruz of the Sandiganbayan Security and Sheriff Services, the Sandiganbayan Security and Sheriff Services vs. Wellex Group, Inc, G.R. No. 247439, August 23, 2023 — read the decision on LawPhil →
- Standard Chartered Bank, Philippine Branch vs. Philippine Investment Two (SPV-AMC) Inc., Philippine Investment One (SPV-AMC), Inc, G.R. No. 216608, April 26, 2023 — read the decision on LawPhil →
- Marissa B. Bacani vs. Rosita D. Madio, G.R. No. 218637, February 1, 2023 — read the decision on LawPhil →