Case Summary (G.R. No. 190828)
Background of Events
In 1995, the rank-and-file employees of TTCI formed the Times Employees Union (TEU). The union initiated a strike in March 1997, which was subsequently halted by a return-to-work order from the then Labor Secretary due to compulsory arbitration. Later developments included a resolution by the TTCI Board, approved on August 23, 1997, to retrench workers, which was attributed to increased operational costs and sustained losses. Notices of retrenchment were issued on September 16, 1997, affecting several employees.
Legal Proceedings and Claims
Following a second strike in October 1997—met with termination notices for 119 participants—TTCI notified the Department of Labor and Employment of its impending closure due to losses. In May 1998, several petitioners filed complaints against TTCI and Mencorp with the National Labor Relations Commission (NLRC), which were initially consolidated under the name "Malana v. TTCI." This was later withdrawn in 1999, and four years after that withdrawal, new complaints were filed in June and July 2002 concerning unfair labor practices, illegal dismissal, and money claims.
Labor Arbiter Decision and Appeals
On June 9, 2005, the Labor Arbiter ruled against the petitioners for unfair labor practice and money claims citing the ground of prescription for some claims. However, some of the complaints regarding illegal dismissal were recognized as timely and granted separation pay and back wages based on the exclusion of pendency. The NLRC later reversed this finding, asserting all complaints had prescribed, as they were filed beyond the four-year limit post-dismissal.
Court of Appeals and Subsequent Rulings
The petitioners' request for reconsideration was denied by the NLRC, prompting an appeal to the Court of Appeals (CA). The CA reaffirmed the NLRC's ruling, reasoning that the four-year prescriptive period had elapsed since the complaints were filed over four years after dismissals. It explicitly rejected the petitioners' argument concerning the tolling of the prescriptive period due to the earlier withdrawal of their original complaint, referencing relevant precedents including the Intercontinental Broadcasting Corporation v. Panganiban case.
Legal Principles and Final Ruling
The central legal issue was whether the petitioners' complaints for illegal dismissal had prescribed. The Supreme Court acknowledged the principle that labor cases should ultimately rely on substantial evid
...continue readingCase Syllabus (G.R. No. 190828)
Background of the Case
- The case revolves around a petition for review that seeks to annul the Decision dated August 28, 2009, and the Resolution dated December 11, 2009, of the Court of Appeals (CA).
- The CA's decision affirmed the ruling of the National Labor Relations Commission (NLRC), which had vacated the Labor Arbiter's (LA) earlier decision that had found some petitioners as illegally dismissed.
- The central issue at hand is whether the complaints for illegal dismissal and related claims have prescribed.
Facts of the Case
- Times Transportation Co., Inc. (TTCI) is engaged in land transportation in the Ilocos Region and employed 21 petitioners in various capacities (e.g., bus drivers, conductors).
- In 1995, a union named Times Employees Union (TEU) was formed and later certified as the sole bargaining unit within TTCI.
- TEU initiated a strike in March 1997 but was ordered back to work by the Secretary of Labor.
- On August 23, 1997, TTCI's Board approved a resolution to dispose of company assets and implement a retrenchment program effective October 1, 1997.
- Following the retrenchment, notices of termination were issued to several employees, and a second strike was declared by TEU on October 17, 1997.
- Notices of termination were issued to 119 workers for participating in the illegal strike.
- On May 14, 1998, several petitioners filed complaints again