Case Summary (G.R. No. 175689)
Summary of Facts
Arriola was employed by Pilipino Star Ngayon, Inc. in July 1986. He held various roles until November 1999, when his column was removed, after which he did not return to work. On November 15, 2002, Arriola filed a complaint claiming illegal dismissal, non-payment of wages, and various damages, asserting that he was dismissed arbitrarily when his column was removed. Pilipino Star Ngayon, Inc. and Belmonte countered that Arriola abandoned his post after failing to report to work following the column's removal.
Proceedings Before Labor Arbiter
The Labor Arbiter ruled against Arriola, finding he had abandoned his employment. Specifically, the Arbiter noted that Arriola's three-year delay in filing the complaint contradicted the typical immediate response of an aggrieved employee. The Arbiter also dismissed Arriola's money claims based on the three-year prescription period under Article 291 of the Labor Code.
National Labor Relations Commission's Decision
On appeal, the National Labor Relations Commission affirmed the decision of the Labor Arbiter. The Commission underscored the absence of any illegal dismissal, reiterating that Arriola's disappearance from work indicated abandonment of his position. The Commission also denied Arriola's motion for reconsideration.
Court of Appeals' Ruling
The Court of Appeals upheld the findings of the lower bodies, supporting the conclusion that Arriola was not illegally dismissed and had, in fact, abandoned his employment. The Court found no errors in the factual determinations made by the Labor Arbiter and the Commission, and also noted that Arriola had not established a valid claim for damages or wages owed due to the alleged illegal dismissal.
Legal Basis for Prescription of Claims
The Supreme Court addressed two main issues: the prescription of Arriola's claims and whether he was illegally dismissed. The Court clarified that claims associated with illegal dismissal, including backwages, are governed by the four-year prescriptive period as established in Article 1146 of the Civil Code—not the three-year limit indicated in Article 291 of the Labor Code. Since Arriola filed his complaint three years and one day after the alleged dismissal, his claims for damages stemming from illegal dismissal had not yet prescribed.
Finding on Abandonment of Employment
The Supreme Court determined that Arriola had abandoned his employment, defined as a "clear, deliberate, and unjustified refusal to continue working." It was concluded that his prolonged absence (from No
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Case Overview
- This case involves George A. Arriola as the petitioner, challenging the decision of Pilipino Star Ngayon, Inc. and Miguel G. Belmonte as respondents regarding claims of illegal dismissal and related monetary claims.
- The Supreme Court's ruling emphasizes that the prescriptive period for filing illegal dismissal complaints is four years, not three years as stipulated for other money claims under Article 291 of the Labor Code.
Factual Background
- Employment History: Arriola was employed by Pilipino Star Ngayon, Inc. since July 1986, eventually becoming a section editor and writer.
- Column Removal: His column "Tinig ng Pamilyang OFWs" was removed from publication on November 15, 1999, after which he did not return to work.
- Filing of Complaint: On November 15, 2002, Arriola filed a complaint for illegal dismissal, non-payment of wages, damages, and attorney’s fees with the National Labor Relations Commission (NLRC).
Claims of Illegal Dismissal
- Arriola’s Allegation: He contended that Pilipino Star Ngayon, Inc. illegally dismissed him when his column was removed, violating his rights to security of tenure and due process.
- Respondent’s Defense: Pilipino Star Ngayon, Inc. argued that Arriola voluntarily absented himself from work and later transferred to a r