Short answer. You have six years. Article 1145 of the Civil Code prescribes that actions upon a quasi-contract must be commenced within six years. The period generally runs from the time the unjust enrichment occurred or from when you became aware of it, depending on the circumstances of your case.
What the law says
The following actions must be commenced within six years: (1) Upon an oral contract; (2) Upon a quasi-contract.
Civil Code, Article 1145 — Six-Year Actions. Read the full provision →
What is a quasi-contract
A quasi-contract is a legal obligation that arises not from an agreement but from the law itself, to prevent unjust enrichment. The two main examples in Philippine law are solutio indebiti — recovering something paid by mistake — and negotiorum gestio, where a person manages another's affairs without authority and is entitled to reimbursement. No contract needs to exist. The obligation arises because allowing one person to keep a benefit at another's expense, without legal basis, is something the law will not permit.
The six-year deadline
Article 1145 of the Civil Code sets the prescriptive period for quasi-contract actions at six years. The clock typically begins when the cause of action arose — meaning when the unjust enrichment happened and you had the right to demand restitution. If you paid an amount you did not owe, the period starts from that payment. If someone used your money or property without authority, it generally starts from the time of that use. Waiting too long extinguishes your right to recover, even if the claim is otherwise meritorious.
What you need to establish your claim
To succeed in a quasi-contract action, you generally need to show three things: (1) the other party received something of value; (2) it came at your expense; and (3) there was no legal justification for them to keep it. Document the enrichment with records — proof of payment, bank transfers, receipts, or anything showing what was transferred and when. Also preserve any communication showing the other party's awareness of the situation or their failure to return the benefit. Absence of a legal basis is often the key disputed issue, so be clear about why no valid agreement or legal right supported what they received.
Act before the six years expires
Prescription is a complete bar to recovery once the period lapses. Courts will not hear an otherwise valid claim if it is filed after the prescriptive period has expired and the defense is raised. If you know you have a quasi-contract claim — someone was unjustly enriched at your expense — do not delay in assessing whether to pursue it. Six years may seem like a long time, but evidence grows stale, witnesses become unavailable, and recovering your losses becomes harder the longer you wait. A lawyer can help you identify when exactly your period started and how much time you have left.
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.
- Commissioner of Internal Revenue vs. San Miguel Corporation/San Miguel Corporation vs. Commissioner of Internal, G.R. No. 180740 / G.R. No. 180910, November 11, 2019 — read the decision on LawPhil →
- Maria L. Anido, et al. vs. Filomeno Negado, et al, G.R. No. 143990, October 17, 2001 — read the decision on LawPhil →
- Francisco L. Rosario, Jr. vs. Lellani De Guzman, Arleen De Guzman, et al, G.R. No. 191247, July 10, 2013 — read the decision on LawPhil →
- Pablo R. Antonio, Jr. vs. Engr. Emilio M. Morales etc, G.R. No. 165552, January 23, 2007 — read the decision on LawPhil →