Philippine National Railways v. National Labor Relations Commission
REITERATIONFacts
The Antecedents: On April 16, 1973, the Court of Industrial Relations (CIR) rendered judgment in an unfair labor practice case, ordering Philippine National Railways (PNR) to reinstate Rodolfo Caldo and two others with full backwages. The judgment became final and executory on September 3, 1974. Pursuant to a PNR Board of Directors' resolution on December 26, 1974, Caldo and his co-complainants were paid back salaries up to April 30, 1974. However, only Caldo's co-complainants were reinstated; Caldo was not. Caldo alleged that he repeatedly demanded re-employment for over twelve years without success. Procedural History: On March 31, 1986, Caldo filed a motion for reconstitution of records and for an alias writ of execution, seeking additional back wages from May 1, 1974, to March 13, 1986, and separation pay. The motion was granted, and a writ of execution was issued on July 15, 1986. PNR raised technical issues, leading to referral to the NLRC-NCR. Caldo filed another motion for an alias writ of execution on December 23, 1986, which was granted by Labor Arbiter Diosana on January 5, 1987. PNR moved to quash the writ, arguing the decision was over ten years old and thus unenforceable by motion. Caldo opposed, citing the destruction of records by fire in December 1983 as a reason for delay. The Labor Arbiter overruled PNR's motion, ordering payment of back wages limited to three years without reinstatement, reasoning that PNR's Board resolution constituted a written acknowledgment that interrupted prescription. The Petition: The NLRC affirmed the Labor Arbiter's decision. PNR filed a petition for certiorari with the Supreme Court, arguing that the judgment was already time-barred and could no longer be executed by motion.
Issue(s)
Whether the judgment in CIR Case No. 5414-ULP had prescribed and was no longer enforceable by motion. Whether the resolution of the PNR Board of Directors dated December 26, 1974, interrupted or suspended the prescriptive period for execution. Whether the destruction of records by fire interrupted the prescriptive period for execution, and the possibility of execution by motion versus independent action.
Ruling
The Supreme Court granted the petition for certiorari, nullified and set aside the Resolution of the NLRC and the Decision of the Labor Arbiter, and declared the attempt to execute the judgment in CIR Case No. 5414-ULP by motion as ineffectual because it was time-barred and, even if not, could no longer be had by motion but by independent action.
Ratio Decidendi
On the prescription of the judgment and enforceability by motion: The Court reiterated that Article 1144 of the Civil Code provides that an action upon a judgment must be brought within ten years from the time the right of action accrues. However, under Rule 39, Section 6 of the Rules of Court, a judgment may be executed by motion within five years from its entry or finality. After five years, and before it is barred by the statute of limitations (which is ten years from finality), it may be enforced by an independent action. In this case, the judgment became final and executory by September 3, 1974. It could have been executed by motion within five years, i.e., until September 3, 1979. It was not. It could have been enforced by an independent action within the next five years, i.e., until September 3, 1984. Caldo filed his motion for reconstitution and execution on March 31, 1986, which was beyond the ten-year prescriptive period. On the interruption of prescription by written acknowledgment: The Court clarified that Article 1155 of the Civil Code, which states that prescription is interrupted by a written acknowledgment of the debt by the debtor, means that the period begins to run anew from the date of interruption. It does not mean that prescription will stop running altogether or be placed in an indefinite state of suspension. The PNR Board resolution of December 26, 1974, approving reinstatement and back wages, was considered a written acknowledgment. However, even if this acknowledgment were to be reckoned from December 26, 1974, the ten-year prescriptive period for enforcement by action would still have expired by December 26, 1984, prior to Caldo's filing of his motion in 1986. Therefore, the respondents' theory that the acknowledgment caused prescription to stop completely was fallacious. On the interruption of prescription by destruction of records and the possibility of execution by motion versus independent action: The Court found Article 1154 of the Civil Code, which provides that the period during which the obligee was prevented by a fortuitous event from enforcing his right is not reckoned against him, inapplicable. The destruction of the records by fire in December 1983 did not prevent Caldo from attempting to reconstitute the records and instituting an action before the expiry of the ten-year period from the finality of the judgment. The filing of the motion for reconstitution and execution in March 1986 was already beyond the ten-year prescriptive period, regardless of the fire. Even if the ten-year period had not yet expired, the Court noted that execution by motion was only possible within the first five years from finality. Since more than five years had elapsed, an independent action would have been necessary to enforce the judgment, not a mere motion. Caldo's filing of a motion for reconstitution and alias writ of execution was therefore ineffectual not only because it was time-barred but also because the procedural remedy sought was no longer appropriate.
Main Doctrine
The interruption of the prescriptive period for the execution of a judgment, as provided by Article 1155 of the Civil Code, renews the period, causing it to run anew from the date of interruption, and does not cause the period to stop running altogether. Furthermore, execution of a judgment by motion is only possible within five years from its entry or finality; thereafter, it must be enforced by an independent action within the ten-year statute of limitations.