Case Digest (G.R. No. 198675)
Facts:
Ilaw Buklod ng Manggagawa (IBM) Nestle Philippines, Inc. Chapter, et al., G.R. No. 198675, September 23, 2015, the Supreme Court Third Division, Peralta, J., writing for the Court. Petitioners are the Ilaw Buklod ng Manggagawa (IBM) Nestle Philippines, Inc. Chapter (union), its officers and dismissed members (including Bonifacio T. Florendo, Emiliano B. Palanas and Generoso P. Laxamana); respondent is Nestle Philippines, Inc..On January 13, 1997 petitioners staged a strike against respondent’s Ice Cream and Chilled Products Division, alleging violations of the collective bargaining agreement, dismissals of union officers and members, discrimination and other unfair labor practices. Respondent filed a Petition for Injunction with Prayer for TRO, free ingress and egress, and deputization with the National Labor Relations Commission (NLRC); the NLRC issued a TRO on January 20, 1997 and a preliminary injunction on February 7, 1997. Respondent also filed a Petition to Declare Strike Illegal on February 26, 1997; on April 2, 1997 the then Acting Secretary of the Department of Labor and Employment (DOLE) assumed jurisdiction over the strike and certified the matter to the NLRC. Petitioners filed a petition for certiorari with the Supreme Court on June 2, 1997 challenging the DOLE order.
After conciliation the parties executed a Memorandum of Agreement (MOA) dated August 4, 1998 resolving their disputes; the MOA included mutual undertakings (withdrawal of court and NLRC actions, payment of accrued benefits subject to releases, recognition of the union, and the dismissal of criminal cases). The parties filed a Joint Motion to Dismiss on August 6, 1998, and on October 12, 1998 the NLRC issued a Decision approving the compromise agreement and granting the joint motion to dismiss.
More than eleven years later, on January 25, 2010, petitioners filed with the NLRC a Motion for Writ of Execution claiming nonpayment under the MOA. Respondent opposed on grounds of prescription under the applicable NLRC rules (a motion for execution lies within five years; thereafter enforceable by independent action within ten years). On November 18, 2010 the NLRC denied the motion for writ of execution for being barred by prescription; its February 14, 2011 resolution denied petitioners’ motion for reconsideration.
Petitioners filed a petition for certiorari with the Court of Appeals (CA) (CA‑G.R. SP No. 118459) challenging the NLRC resolutions, principally asserting that their claim was not time‑barred. On June 30, 2011 the CA dismissed the certiorari petition as a wrong mode of appeal, holding that the matter raised a pure question of law appropriate for direct recourse to the Supreme Court via Rule 45; th...(Subscriber-Only)
Issues:
- Was the CA correct in dismissing petitioners’ certiorari petition as the wrong mode of appeal?
- Is petitioners’ claim to enforce the NLRC Decision approving the MOA barred by prescription?
- If prescription applies, did respondent’s alleged conduct interrupt or toll the prescriptive period so as to ex...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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