Case Digest (G.R. No. L-13419)
Facts:
Casiano Saladas v. Franklin Baker Company, G.R. No. L-13419. May 30, 1960, the Supreme Court En Banc, Concepcion, J., writing for the Court.Plaintiff-appellant Casiano Saladas was employed by defendant-appellee Franklin Baker Company from December 7, 1949 until his dismissal on June 2, 1952. After his dismissal, Saladas filed a claim with the Wage Administration Service, Department of Labor, for unpaid overtime allegedly earned during his employment; that office on August 4, 1953 found him entitled to P3,799.52 and, by letter dated October 27, 1954, formally demanded payment from Franklin Baker Company.
When the company did not pay, Saladas instituted Civil Case No. Q-1299 in the Court of First Instance (CFI) of Rizal on November 23, 1954 for recovery of the sum. The case was set for hearing, but on January 5, 1956 plaintiff, through the Department of Labor prosecutor, moved for continuance because the assigned prosecutor was unavailable; the motion was denied and, by order dated January 9, 1956, the CFI dismissed the case (apparently without prejudice). On July 18, 1957 Saladas filed the present action in the CFI to recover the same overtime claim.
In its amended answer Franklin Baker Company pleaded, inter alia, that the claim had prescribed. After a preliminary hearing on prescription the trial court issued the order dismissing the case as barred by the statute of limitations. Saladas appealed to the Supreme Court by petition (appeal) from that dismissal. The main contested facts before the Court were the dates of accrual of the overtime causes...(Subscriber-Only)
Issues:
- Did Republic Act No. 1993, which prescribed a three-year limitation for actions under the Eight-Hour Law, operate to bar plaintiff’s claim that accrued before its approval?
- Did the written extrajudicial demand of October 27, 1954 and the institution (and later dismissal) of Civil Case No. Q-1299 interrupt or suspend prescription as to plaintiff’s overtime claims under Article 1155 of the Civil Code?
- When did plaintiff’s cause of action for overtime accrue, and, applying the applicable rules, was any portion of his cl...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
- (Subscriber-Only)