Nator v. Court of Industrial Relations
REITERATIONFacts
The Antecedents: On August 6, 1953, hotel employees filed a complaint with the Court of First Instance (CFI) of Cebu against the owners of 'La Suerte Hotel' for underpayment, overtime pay, separation pay, moral damages, and attorney's fees. The CFI rendered judgment in favor of the employees. The owners appealed to the Court of Appeals (CA). Due to the loss of stenographic notes by fire, the CA remanded the case to the CFI for re-trial. Procedural History: On August 30, 1958, the CFI issued an order declaring itself without jurisdiction to re-try the case, citing Supreme Court rulings on the exclusive jurisdiction of the Court of Industrial Relations (CIR) over cases involving the Minimum Wage Law. The CFI dismissed the case without prejudice. A petition for Mandamus and Prohibition filed with the Supreme Court to compel the CFI to re-try the case was dismissed, stating that appeal was the proper remedy. The Petition: On December 5, 1958, the employees filed a new claim with the CIR against the hotel owners, raising similar causes of action: underpayment, overtime pay, separation pay, damages, and attorney's fees. The hotel owners raised defenses of no cause of action, prescription, and bar by prior judgment. The CIR rendered judgment in favor of the employees. The owners appealed to the Supreme Court.
Issue(s)
Whether or not the action filed with the CIR has already prescribed. Whether or not the action filed with the CIR has been barred by previous judgment.
Ruling
The Supreme Court ruled that the causes of action of the respondents have not prescribed nor have they been barred by a former judgment. The Court returned the case to the CFI of Cebu to conduct a hearing for the purpose of retaking lost testimonies, and thereafter, to forward the same to the Court of Appeals for decision.
Ratio Decidendi
On the issue of prescription: The Court held that the filing of the complaint with the CFI on August 6, 1953, interrupted the prescriptive period for the employees' claims. This interruption lasted until August 30, 1958, when the CFI dismissed the case for lack of jurisdiction. The prescriptive period began to run again on August 30, 1958. Since the complaint was filed with the CIR on December 5, 1958, the action had not yet prescribed. The Court emphasized that the bringing of an action in a court without jurisdiction does not necessarily mean the prescriptive period is not interrupted, especially when the parties were pursuing available remedies sanctioned by jurisprudence at the time. The Court also noted an exception in Section 7-a of Commonwealth Act No. 444, as amended by Republic Act No. 1993, which states that actions commenced before the effective date of the Act shall not be affected by the prescribed period. On the issue of bar by former judgment (res judicata): The Court found that the dismissal of the Mandamus and Prohibition case by the Supreme Court was not on the merits, as it merely stated that 'appeal in due time being the proper remedy.' For a judgment to be a bar to a subsequent action, it must be final, rendered by a competent jurisdiction, one on the merits, and involve identity of parties, subject-matter, and causes of action. In this instance, there was no hearing on the merits before the CFI dismissed the case for lack of jurisdiction, and the subsequent Supreme Court resolution did not pass upon the merits of the claims. Therefore, the elements of res judicata were not met.
Main Doctrine
The filing of a case in a court without jurisdiction interrupts the period of prescription until the dismissal for lack of jurisdiction becomes final. The period of prescription begins to run again from the cessation of the interruption.