Case Digest (G.R. No. 132257)
Facts:
Amado De Guzman and Manila Workers Union and General Workers Union (MALEGWU) v. Court of Appeals and Nasipit Lumber Company, G.R. No. 132257, October 12, 1998, Supreme Court First Division, Panganiban, J., writing for the Court. The petition for review on certiorari assailed the July 4, 1997 decision of the Court of Appeals (CA-GR SP No. 42952, Second Division, Salas, J., ponente) which reversed a decision of the Voluntary Arbitrator.The petitioners are rank-and-file employees (and their union) who were placed on forced leave following a partial suspension of operations by Nasipit Lumber Company on April 16, 1992. The union sent letters (dated April 4 and April 7, 1992) characterizing the forced leave as a grievance under the parties’ Collective Bargaining Agreement (CBA) raising issues of optional retirement and separation pay. The employees filed a case for illegal forced leave before the NLRC/Labor Arbiter on June 2, 1992 (NLRC Case No. 00-06-03067-92). The company moved to dismiss for lack of jurisdiction, invoking the Voluntary Arbitrator’s exclusive jurisdiction under Article 261 of the Labor Code; the Labor Arbiter denied the motion.
A related case was filed December 7, 1992 (NLRC Case No. 00-12-06862-92) for illegal dismissal or, alternatively, payment of CBA benefits. On November 9, 1994 the Labor Arbiter dismissed but ordered retrenchment benefits (P206,959.19). On appeal the NLRC (March 31, 1995) affirmed, but noted that interpretation of certain CBA provisions on retirement had been submitted to voluntary arbitration in another matter (decision of Voluntary Arbitrator Ramon T. Jimenez, October 12, 1993), which the Supreme Court later declined to disturb (petition for certiorari dismissed in G.R. No. 106933 and reconsideration denied in 1994).
At the petitioners’ instance the dispute eventually went to the Voluntary Arbitrator, who rendered a decision on July 16, 1996 awarding optional retirement benefits to two employees and separation assistance to three others, computed by reference to the CBA formula. The company’s motion for reconsideration was denied December 2, 1996, and it elevated the matter to the Court of Appeals. The Court of Appeals reversed the Voluntary Arbitrator on the ground that petitioners’ money claims arising from the employment relation were governed by the three-year prescriptive period of Article 291 of the Labor Code and therefore had prescribed; it held that filings before t...(Pro-only)
Issues:
- Is the petitioners’ cause of action for unpaid CBA retirement/separation benefits governed by the ten‑year prescriptive period of Article 1144 of the Civil Code or by the three‑year prescriptive period of Article 291 of the Labor Code, and did the filing of cases before the Labor Arbiter/NLRC interrupt prescription?
- If petitioners’ claims are not prescribed, are they entitled to the optional retirement and separation assistance benefits under Article V, Sections 12 and 13 of the CBA, and if so, at wh...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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