Pepsi Cola Bottling Company of the Philippines v. Guanzon
REITERATIONFacts
The Antecedents: Petitioner Pepsi Cola Bottling Company of the Philippines (PEPSI) hired private respondent Job Guanzon as a route salesman on September 12, 1965. In June 1979, Guanzon was suspended for alleged violation of company rules. An administrative investigation found him guilty of misappropriating customer collections and falsifying invoices. On July 6, 1979, PEPSI served Guanzon a letter terminating his employment effective July 17, 1979. PEPSI also filed a criminal complaint for Estafa Through Falsification of Commercial Documents against Guanzon, which was dismissed on May 25, 1984, on the grounds that a charge invoice is not a commercial document and that Guanzon had already paid his financial liability. Procedural History: On November 14, 1984, Guanzon filed a complaint for reinstatement, backwages, and damages, claiming he was unlawfully dismissed due to fabricated charges. The Labor Arbiter dismissed the complaint, holding that the claims had prescribed under Article 292 of the Labor Code. On appeal, the National Labor Relations Commission (NLRC) reversed the Labor Arbiter's decision, ruling that the complaint was for illegal dismissal and reinstatement, not merely money claims, and thus governed by the four-year prescriptive period under Article 1146 of the Civil Code. The NLRC considered the dismissal of the criminal case on May 25, 1984, as the reckoning date, finding that the complaint filed on November 14, 1984, was within the prescriptive period. The NLRC also found Guanzon's dismissal to be without just cause and violative of due process. Since reinstatement was impractical, the NLRC ordered payment of three years' backwages and separation pay. The Petition: PEPSI filed a petition for certiorari, assailing the NLRC decision and arguing that Guanzon's action for illegal dismissal had prescribed.
Issue(s)
Whether private respondent Job Guanzon's action for illegal dismissal had prescribed. Whether the National Labor Relations Commission erred in considering the dismissal of the criminal case as the reckoning date for the prescriptive period of the illegal dismissal case. Whether petitioner PEPSI waived its right to interpose the defense of prescription.
Ruling
The Supreme Court granted the petition, set aside the NLRC decision, and reinstated the Labor Arbiter's decision dismissing the complaint. The Court ruled that the action for illegal dismissal had prescribed.
Ratio Decidendi
On the issue of prescription: The Court held that private respondent's action for illegal dismissal was barred by prescription. The cause of action for illegal dismissal accrued on July 17, 1979, the effective date of termination. Guanzon filed his complaint on November 14, 1984, more than five years after his dismissal. This period exceeded both the three-year prescriptive period for money claims under the Labor Code and the four-year period under Article 1146 of the Civil Code, which the NLRC erroneously applied. The Court emphasized that Guanzon could have immediately challenged his dismissal without waiting for the outcome of the criminal case. On the reckoning date for prescription: The Court disagreed with the NLRC's position that the dismissal of the criminal case on May 25, 1984, was the reckoning date. The Court reiterated that in illegal dismissal cases, the cause of action accrues from the time the employee was unjustly terminated, which was July 17, 1979. The filing of a criminal case for estafa and falsification did not suspend or interrupt the prescriptive period for filing an action for illegal dismissal, as these are separate and distinct administrative and criminal actions. The guilt or innocence in the criminal case is not determinative of the existence of a just or authorized cause for dismissal. On the waiver of the defense of prescription: The Court found no merit in the contention that PEPSI waived its defense of prescription. The Court noted that the Labor Code and NLRC Rules do not provide a specific period for filing a motion to dismiss. Furthermore, even if the motion to dismiss was filed out of time, the Court held that the Labor Arbiter could still dismiss the case motu proprio because the complaint itself clearly showed that the action had prescribed. The allegations in Guanzon's complaint indicated his dismissal in 1979, while the complaint was filed in 1984, making the prescription evident on the face of the pleading.
Main Doctrine
The cause of action for illegal dismissal accrues from the date of termination, and the filing of a criminal case does not suspend or interrupt the prescriptive period for filing an action for illegal dismissal. A motion to dismiss based on prescription may be acted upon motu proprio by the court if the complaint itself shows that the action has prescribed.