Short answer. You have ten years from the time your right of action accrues. An action upon an obligation created by law is one of the three categories the statute expressly gives this ten-year prescriptive period, distinct from — but treated the same as — an action on a written contract.
What the law says
The following actions must be brought within ten years from the time the right of action accrues: (1) Upon a written contract; (2) Upon an obligation created by law; (3) Upon a judgment.
Civil Code, Article 1144 — Ten-Year Actions. Read the full provision →
Obligations created by law get the same ten years as a written contract
The statute names three categories of actions entitled to a ten-year period: those upon a written contract, those upon an obligation created by law, and those upon a judgment. Your situation — a duty the law itself imposes on someone, rather than one the parties agreed to by contract — falls into the second category. The absence of a contract does not shorten your time to sue; the law gives this category the identical ten-year period.
What distinguishes an obligation created by law
An obligation created by law arises independently of any agreement between the parties — it exists because a statute imposes the duty directly, rather than because the parties bargained for it. This differs from an obligation arising from a contract, where the parties themselves define the duty, and from a judgment, where a court has already adjudicated the obligation. The ten-year period applies regardless of which of these three sources gave rise to the underlying obligation.
The trigger is accrual of the right of action
The ten years runs from the time the right of action accrues — the point at which you could actually have brought your action, not necessarily the date the law imposing the obligation first took effect. Where the legally created duty is a continuing one, or where a breach only becomes apparent later, identifying exactly when accrual happened is often the key question in determining whether the ten-year period has already run out.
What this article does not do
This provision fixes the period and its trigger; it does not itself identify which specific statutes create obligations falling into this category, nor does it address obligations governed by their own special prescriptive periods set out elsewhere in the law. Where another statute specifically provides a different period for a particular obligation it creates, that special period, rather than this general ten-year rule, would ordinarily control.
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.
- Multi-realty Devt. Corp. vs. The Makati Tuscany Condo. Corp, G.R. No. 146726, June 16, 2006 — read the decision on LawPhil →
- Menandro B. Laureano vs. Court of Appeals & Singapore Airlines, Ltd, G.R. No. 114776, February 2, 2000 — read the decision on LawPhil →
- Amado De Guzman and Manila Workers Union and General Workers Union (MALEGWU) vs. Court of Appeals and Nasipit Lumber Company, G.R. No. 132257, October 12, 1998 — read the decision on LawPhil →
- Estate of Susano J. Rodriguez, represented by its Attorney-in-Fact Virgilio R. Valenzuela vs. Republic, G.R. No. 214590, April 27, 2022 — read the decision on LawPhil →