DISCLAIMER: This article does not create an attorney-client relationship between the author and the reader. The answer of the author on the issue is just an expression of his general opinion based on Philippine law and hence does not constitute legal advice.

Part of my job in the corporate is to review contracts. The duration of contract I usually encounter with has specific dates like a contract with a term “December 1, 2024 to May 31, 2025”. What if the covered period has no specific dates like a contract with a term “six months starting from the date of signing”. If the date of signing is December 1, 2024, what is the end of the contract? Is it May 31, 2025?
Following the Supreme Court computation of prescription from the finality of judgment in Abello v. Banco Filipino Savings and Mortgage Bank, G.R. No. 232706 Notice, July 18, 2022, the correct end of the contract is not May 31, 2025 but May 30, 2025, computed as follows (6 months x 30 days = 180 days):

The above computation is based on Article 13 of the Civil Code which provides:
ARTICLE 13 of the Civil Code:
When the laws speak of years, months, days or nights, it shall be understood that years are of three hundred sixty-five days each; months, of thirty days; days, of twenty-four hours; and nights from sunset to sunrise.
If months are designated by their name, they shall be computed by the number of days in which they respectively have.
In computing a period, the first day shall be excluded, and the last day included.
While Section 31 of the Administrative Code of 1987 also provides for a manner on how a legal period is to be computed, this provision applies only in particular to periods embraced within the Administrative Code, including prescription of proceedings or appeals in administrative cases (Abello v. Banco Filipino Savings and Mortgage Bank, G.R. No. 232706 Notice, July 18, 2022). As reference, Section 31 of the Administrative Code of 1987 provides:
SECTION 31 of the Administrative Code:
Legal Periods. — “Year” shall be understood to be twelve calendar months; “month” of thirty days, unless it refers to a specific calendar month in which case it shall be computed according to the number of days the specific month contains; “day,” to a day of twenty-four hours; and “night,” from sunset to sunrise.
April 24, 2025



Leave a comment