Short answer. You have ten years from the time your right of action accrues to file a case upon a written contract. This is the longer of the two prescriptive periods the Civil Code gives to contracts, compared to the shorter period that applies when a contract was only oral.
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 →
Ten years for an action on a written contract
The statute lists an action upon a written contract as the first of three categories entitled to a ten-year prescriptive period, running from the time the right of action accrues. Because your agreement was reduced to writing, an action to enforce it falls within this category, giving you the full ten years to bring suit rather than a shorter period.
Why the writing matters
The distinction between a written and an unwritten contract matters because the law does not give every contractual claim the same amount of time. A written contract benefits from this longer ten-year period precisely because it is written — the existence and terms of the obligation are more readily provable, which is part of why the law is comfortable extending a longer window to sue on it compared to an oral agreement.
When the period starts running
The ten years counts from the time the right of action accrues — ordinarily the point at which the other party breaches the contract or otherwise fails to perform what was due, not necessarily the date the contract was signed. If your contract calls for performance at a future date, or in installments, the accrual of the right to sue for a particular breach is tied to when that specific obligation became due and was not met.
What this article does not decide
This provision fixes the length of the period and its trigger; it does not itself resolve whether a particular document actually qualifies as a written contract, nor does it address situations where a different, more specific statute sets its own prescriptive period for a particular type of written agreement. Where a special law governs the specific kind of contract at issue and prescribes a different period, that special rule would ordinarily take precedence over this general one.
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 →