Case Digest (G.R. No. 175689)
Facts:
George A. Arriola v. Pilipino Star Ngayon, Inc. and/or Miguel G. Belmonte, G.R. No. 175689, August 13, 2014, Supreme Court Third Division, Leonen, J., writing for the Court. Petitioner is George A. Arriola; respondents are Pilipino Star Ngayon, Inc. and Miguel G. Belmonte.In July 1986, petitioner Arriola was employed by respondent Pilipino Star Ngayon, Inc. in various editorial capacities and wrote the column "Tinig ng Pamilyang OFWs" until the column was removed from publication on November 15, 1999. Arriola did not report for work after that date. On November 15, 2002 he filed with the National Labor Relations Commission (NLRC) a complaint for illegal dismissal, nonpayment of salaries/wages, moral and exemplary damages, actual damages, attorney’s fees, and full backwages, alleging he was a regular employee illegally dismissed on November 15, 1999; respondents denied illegal dismissal and asserted that Arriola abandoned his employment and later wrote for a rival paper.
Labor Arbiter Fatima Jambaro‑Franco dismissed Arriola’s complaint in a decision dated July 16, 2003, finding laches and abandonment and ruling that Arriola’s money claims were barred by prescription under Article 291 of the Labor Code (three-year period). The NLRC affirmed the Labor Arbiter’s decision and denied reconsideration. Arriola then filed a petition for certiorari with the Court of Appeals (CA-G.R. SP No. 91256). The Court of Appeals, while noting that factual issues are generally beyond Rule 45 review, nonetheless resolved the facts on the merits in a decision dated August 9, 2006: it found no illegal dismissal, held that the removal of the column was a management prerogative and did not terminate employment, and concluded Arriola abandoned his post; it also held his money claims prescribed under Article 291. The CA denied Arriola’s motion for reconsideration in a resolution dated November 24, 2006.
Arriola filed a petition for review on certiorari under Rule 45 before the Supreme Court contesting (1) prescription of his money claims and (2) the finding of no illegal dismissal/abandonment. He submitted (a) a faxed statement of account allegedly showing computation of separation pay through November 30, 1999, ...(Pro-only)
Issues:
- Did Arriola’s claims for backwages, damages, and attorney’s fees arising from alleged illegal dismissal prescribe when he filed his complaint on November 15, 2002?
- Was Arriola illegally dismissed by Pilipino Star Ngayon, Inc., or did he abando...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)