Arriola v. Pilipino Star Ngayon
REITERATIONFacts
The Antecedents: George A. Arriola was employed by Pilipino Star Ngayon, Inc. (PSN) as a correspondent in July 1986. He held various positions, eventually becoming a section editor and writer. His column, "Tinig ng Pamilyang OFWs," was removed from publication on November 15, 1999, after which he allegedly stopped reporting for work. Procedural History: On November 15, 2002, Arriola filed a complaint for illegal dismissal, non-payment of salaries, damages, attorney's fees, and backwages. The Labor Arbiter dismissed the complaint, finding that Arriola abandoned his employment and that his money claims had prescribed under Article 291 of the Labor Code due to filing one day late. The National Labor Relations Commission (NLRC) affirmed the Labor Arbiter's decision. The Court of Appeals (CA) also affirmed the NLRC's ruling, finding no illegal dismissal and that Arriola abandoned his employment, while also ruling that his money claims had prescribed. The Petition: Arriola filed a petition for review on certiorari with the Supreme Court, arguing that he was illegally dismissed, did not abandon his employment, and that his money claims had not prescribed. He contended that the prescriptive period for backwages and damages should be four years under Article 1146 of the Civil Code, and that his filing was within this period. He also presented a certification from a rival newspaper indicating he only started writing for them in 2003, after filing his complaint.
Issue(s)
Whether Arriola's money claims have prescribed. Whether Pilipino Star Ngayon, Inc. illegally dismissed Arriola.
Ruling
The petition is DENIED. The Court of Appeals' decision dated August 9, 2006 and resolution dated November 24, 2006 in CA-G.R. SP No. 91256 are AFFIRMED.
Ratio Decidendi
On Whether Arriola's money claims have prescribed: The Supreme Court ruled that Arriola's claims for unpaid salaries had prescribed because they were filed three years and one day after his alleged dismissal, exceeding the three-year prescriptive period under Article 291 of the Labor Code. However, the Court clarified that claims for backwages, damages, and attorney's fees arising from an illegal dismissal are governed by Article 1146 of the Civil Code, which provides a four-year prescriptive period. Since Arriola filed his complaint three years and one day after his alleged dismissal, his claims for backwages, actual, moral, and exemplary damages, and attorney's fees were filed within the four-year prescriptive period and thus had not prescribed. The Court of Appeals erred in finding these claims to have prescribed. On Whether Pilipino Star Ngayon, Inc. illegally dismissed Arriola: The Supreme Court affirmed the findings of the lower tribunals that Arriola abandoned his employment and was not illegally dismissed. The Court reiterated that issues of illegal dismissal and abandonment are factual matters generally not subject to review in a petition for certiorari under Rule 45, unless exceptions apply. The removal of Arriola's column was an exercise of management prerogative, and his employment was not dependent on the existence of that specific column. Furthermore, Arriola's failure to report for work after November 15, 1999, and his filing of the complaint three years later, demonstrated a clear intention to sever his employment, constituting abandonment. The Court distinguished this case from others where employees immediately took steps to remedy their dismissal.
Main Doctrine
The prescriptive period for filing an illegal dismissal complaint, including claims for backwages and damages, is four (4) years from the time the cause of action accrued, as provided under Article 1146 of the Civil Code, and not the three (3) year period under Article 291 of the Labor Code which applies only to money claims arising from employer-employee relations, excluding those consequent to illegal dismissal.