Title
Santos vs. Court of Appeals
Case
G.R. No. L-47750
Decision Date
Feb 29, 1980
Marciana Santos, dismissed in 1973, filed for illegal dismissal in 1976. SC ruled her claim, governed by Civil Code's 4-year prescriptive period, was timely, upholding her security of tenure and ordering reinstatement.

Case Digest (G.R. No. L-47750)
Expanded Legal Reasoning Model

Facts:

  • Employment and Dismissal:
Petitioner Marciana Santos was dismissed by private respondent San Miguel Corporation in June 1973. The company justified the dismissal by claiming that Santos and her co-workers were hired for a fixed period of six months, after which their services could be legally terminated.
  • Filing of Complaint:
On April 27, 1976, Santos and her co-workers filed a complaint for illegal dismissal with the Department of Labor. The Hearing Officer ruled in favor of the complainants, stating that the security of tenure clause applied and ordered their reinstatement.
  • Appeal to the Secretary of Labor:
San Miguel Corporation appealed the decision to the Secretary of Labor. The company raised an additional defense against Santos, arguing that her claim was barred by prescription since she had only one year to file her claim under the Labor Code. Santos had been dismissed in June 1973, and her complaint was filed in April 1976.
  • Decision of the Secretary of Labor:
Respondent Secretary of Labor Blas F. Ople dismissed Santos' claim for being filed out of time but ordered the reinstatement of the other complainants. Santos and the company appealed to the Office of the President, which sustained the Secretary of Labor's decision.
  • Certiorari Proceeding:
Santos filed a certiorari proceeding with the Supreme Court, seeking reinstatement. The Solicitor General, representing the public respondents, supported Santos' position, arguing that the one-year prescriptive period under the Labor Code applied only to money claims, not to cases involving injury to rights, which are governed by the Civil Code's four-year prescriptive period.

Issues:

  • Prescription of Claims:
Whether the one-year prescriptive period under the Labor Code applies to Santos' claim for reinstatement, or whether the four-year prescriptive period under the Civil Code governs her case.
  • Security of Tenure:
Whether Santos' dismissal violated her constitutional right to security of tenure and whether she is entitled to reinstatement.
  • Interpretation of Labor Code Provisions:
Whether the Labor Code's provision on the prescriptive period for money claims should be narrowly interpreted to exclude claims for reinstatement and other non-monetary remedies.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Conclusion:

The Supreme Court set aside the decision of the Secretary of Labor and the Office of the President, declaring Santos' dismissal null and void. She was ordered reinstated, and the decision was immediately executory. The Court reaffirmed the importance of protecting workers' rights and ensuring that labor laws are interpreted in a manner consistent with the Constitution.

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