Short answer. From finality. Article 1152 provides that the period for prescription of actions to demand the fulfilment of an obligation declared by a judgment commences from the time the judgment became final. Not from the date it was rendered, and not from the day you received a copy of it.
What the law says
The period for prescription of actions to demand the fulfillment of obligation declared by a judgment commences from the time the judgment became final.
Civil Code, Article 1152 — Actions Upon a Judgment. Read the full provision →
Finality is a date you have to establish
The article does not say from rendition, from promulgation or from receipt. It says from the time the judgment became final. That is a specific event, and in a contested case it depends on what happened afterwards: whether an appeal or a motion was taken, when it was resolved, and when the period to question the decision expired. A litigant who assumes the date on the face of the decision is the starting point can be years out. The entry of judgment is the document that ordinarily records finality, and it is the one to obtain.
The length comes from a neighbouring article
Article 1144 requires an action upon a judgment to be brought within ten years from the time the right of action accrues, and this article tells you when that accrual happens. The two work as a pair: ten years, counted from finality. Note as well that this article speaks of an action to demand fulfilment of the obligation the judgment declared — a fresh action upon the judgment — rather than of enforcing the judgment inside the case where it was obtained.
Enforcement is not only a question of prescription
That distinction matters, because the machinery for enforcing a judgment in the case where it was won runs on the procedural rules and on their own timetable, which in practice is shorter than the Code's period. A judgment creditor sitting comfortably on ten years may find the straightforward route closed long before, leaving only the heavier one. So the question to put to a lawyer is not simply whether the judgment has prescribed, but which method of enforcement is still open and what each of them now requires.
Get the record first
A certified copy of the decision, the entry of judgment, and the docket history showing every motion and appeal and how each was resolved — those together establish the date of finality, which is the fact this article turns on. Then whatever shows what has happened since: any writ issued, any levy, any partial satisfaction, and any written acknowledgment by the judgment debtor. If the debtor has acknowledged the obligation in writing at any point, that is worth surfacing early rather than late.
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.
- Edgardo A. Quilo and Adnaloy Villahermosa vs. Teodula Bajao, G.R. No. 186199, September 7, 2016 — read the decision on LawPhil →
- Rufa A. Rubio, et al. vs. Lourdes Alabata, G.R. No. 203947, February 26, 2014 — read the decision on LawPhil →
- Ernesto Villeza vs. German Management and Services, Inc., et al, G.R. No. 182937, August 8, 2010 — read the decision on LawPhil →
- Lucila David and the Heirs of Rene F. Aguas, namely: Princess Luren D. Aguas, G.R. No. 241036, January 26, 2021 — read the decision on LawPhil →