Montero v. Times Transportation Co.
REITERATIONFacts
The Antecedents: Respondent Times Transportation Co., Inc. (TTCI) employed twenty-one (21) individuals as drivers, conductors, mechanics, welders, security guards, and utility personnel. In March 1997, union members went on strike, which was later ended by a return-to-work order. Subsequently, TTCI's Board of Directors approved a resolution to gradually dispose of company assets due to increasing operational costs and losses. This led to a company-wide retrenchment program, and the sale of 25 buses and their Certificates of Public Convenience to respondent Mencorp Transport Systems, Inc. (MENCORP). In October 1997, the union declared a second strike, resulting in the termination of 119 workers for participating in an illegal strike. On December 4, 1997, TTCI notified the Department of Labor and Employment of its impending closure due to heavy business losses. Procedural History: On May 14, 1998, some of the petitioners filed complaints against TTCI and MENCORP, which were consolidated. This case was later withdrawn on March 4, 1999. Four years later, from June to July 2002, several consolidated complaints for unfair labor practice, illegal dismissal, and money claims were filed against TTCI, its president Santiago Rondaris, MENCORP, and its General Manager Virginia Mendoza and her husband Reynaldo Mendoza. TTCI argued prescription, while MENCORP denied an employer-employee relationship. The Labor Arbiter (LA) dismissed some claims due to prescription but found ten petitioners were illegally dismissed, awarding them separation pay and backwages. The National Labor Relations Commission (NLRC) vacated the LA's decision, finding all complaints prescribed. The Court of Appeals (CA) affirmed the NLRC's decision, dismissing the petition for certiorari. The petitioners then filed the present petition for review on certiorari. The Petition: The petitioners seek to annul and set aside the Decision of the Court of Appeals, which affirmed the NLRC's ruling that their complaints for illegal dismissal had prescribed. The core issue is whether the period during which their initial labor case was pending, and subsequently withdrawn, should be excluded from the four-year prescriptive period for filing illegal dismissal claims. The petitioners argue that the withdrawal of their initial complaint should not negate the tolling of the prescriptive period. The respondents maintain that the withdrawal effectively reset the prescriptive clock, rendering the subsequent filing of complaints untimely. This petition is filed under Rule 45 of the Rules of Court, seeking a review of the CA's decision.
Issue(s)
Whether the petitioners' complaints for illegal dismissal have already prescribed. Whether the period during which the petitioners' first case was pending should be excluded from the computation of the four-year prescriptive period for illegal dismissal cases, considering its voluntary withdrawal.
Ruling
The petition is bereft of merit. The Supreme Court affirmed the Decision of the Court of Appeals which upheld the National Labor Relations Commission's ruling that the petitioners' complaints for illegal dismissal had already prescribed.
Ratio Decidendi
On the issue of prescription of illegal dismissal complaints: The Court reiterated that an action for illegal dismissal must be brought within four years from the time of dismissal, as per Article 1146 of the New Civil Code. The petitioners' employment was terminated in October and November 1997, but their complaints were filed in June 2002, beyond the four-year period. The Court found that the complaints had prescribed. On the issue of excluding the period of the first case: The Court applied the principle from Intercontinental Broadcasting Corporation v. Panganiban, stating that the voluntary withdrawal of a complaint leaves the parties as if no action had commenced. The withdrawal of the May 14, 1998 complaint on March 22, 1999, erased any tolling of the prescriptive period. The four-year period continued to run, and by the time the 2002 complaints were filed, the cause of action had prescribed. While social justice favors the working class, justice is for the deserving, based on facts, law, and doctrine. The petitioners' withdrawal led to the prescription of their claims.
Main Doctrine
The voluntary withdrawal of a labor complaint leaves the parties in the same position as though no action had been filed, effectively canceling the tolling of the prescriptive period for filing the same cause of action.