G.R. No. 202158 - Alvarez vs. Golden Tri Block Inc.

Petitioners: Teekay Shipping Philippines, Inc. and Teekay Shipping Canada, Ltd.
Private Respondent: Ramier C. Concha, hired as an Able Seaman under an employment contract.
Employment terms:

On a windy morning of 23 November 2000, while performing deck duties, a foreign particle accidentally entered the respondent’s left eye.
The designated medical officer on board administered first aid when the respondent’s eye became reddish and his vision blurred.
With no improvement after first aid, the respondent requested and obtained further medical evaluation.

On 3 December 2000, the respondent was admitted at Karanatha Hospital in Australia and was initially diagnosed with Left Eye Acute Iritis.
He was then referred to the Royal Perth Hospital, West Australia, where he was diagnosed with Left Eye Iritis (Granulomatous).

On 6 December 2000, having been deployed for less than a month, the respondent was repatriated to the Philippines.
Upon arrival, he was referred to the Metropolitan Hospital and underwent medical treatment until February 2001.

On 28 May 2001, the respondent filed his first complaint for illegal dismissal with money claims before the Arbitration Branch of the NLRC; the complaint was dismissed without prejudice on the same day.
On 13 December 2004, he refiled a complaint for illegal dismissal seeking:

Petitioners moved to dismiss the 13 December 2004 complaint on the ground that it was time-barred, citing Article 291 of the Labor Code which provides for a three (3) year prescription for money claims.
The Labor Arbiter dismissed the complaint via an Order on 28 February 2005 on the ground of prescription.
On 11 April 2005, the respondent filed an appeal to the NLRC arguing that the dismissal was erroneous and that he was denied the opportunity to present evidence.

On 28 November 2006, the NLRC issued a Resolution setting aside the earlier dismissal and reinstated the case, ordering further proceedings at the Arbitration Branch.
Petitioners’ Motion for Reconsideration was denied by the NLRC on 31 January 2007.
Petitioners assailed these NLRC resolutions before the Court of Appeals (CA).
The CA issued a decision on 3 July 2008 dismissing petitioners’ appeal, and a subsequent motion for reconsideration filed on 25 July 2008 was denied in a Resolution dated 20 November 2008.

Whether or not the Court of Appeals erred in ruling that the private respondent’s claims had not yet prescribed.

Examination of the appropriate applicable prescriptive period for a claim for illegal dismissal.
Determination of when the cause of action accrued—whether pursuant to the POEA Standard Employment Contract’s three‐year period or the four‐year period under Article 1146 of the Civil Code for injuries to rights.