Title
Saladas vs. Franklin Baker Co.
Case
G.R. No. L-13419
Decision Date
May 30, 1960
Employee dismissed in 1952 sought overtime pay; claim initially dismissed, refiled in 1957. Court ruled statute of limitations interrupted by prior demand and filing, allowing timely claim under amended law.

Case Summary (G.R. No. 150780)

Procedural History and Lower Court's Decision

Casiano Saladas appealed the dismissal of his case by the Court of First Instance of Rizal, which ruled that his claim for overtime compensation was barred by the statute of limitations. Saladas was an employee of Franklin Baker Company and claimed overtime compensation for the period of his employment prior to his termination in 1952. After an initial claim with the Wage Administration Service was unaddressed by the company, he sought to recover the amount in court.

Relevant Legislation

At the time of the claim, the statute of limitations for bringing an action for overtime compensation was notably contentious. Following the enactment of Republic Act No. 1993 on June 22, 1957, the limitations period for such claims was amended from six years to three years. This statue raised questions regarding its application to claims that accrued before its approval, directly impacting Saladas’ case.

Issues of Statutory Limitations

The crux of the appeal centered on whether Saladas' claim was indeed time-barred under the new three-year limitation period. His initial assertion relied upon the prescriptive period existing when his cause of action accrued, maintaining that under prior law, he had six years to file his claim. The defendant countered that this period had been effectively reduced, and thus, Saladas’ claim was stated to be expired given the timeline of events.

The Proviso of Republic Act No. 1993

Saladas argued that the amendment to the law should be applied prospectively and not retroactively to affect actions that had accrued prior to its enactment. Yet the text of Republic Act No. 1993 specifically indicated that it should apply to actions instituted after its approval, thereby limiting the prescriptive period uniformly across claims, a point which the court found significant in its analysis.

Constitutional Concerns

Saladas contested the constitutionality of retroactively applying the new statute of limitations, claiming it denied him due process and impaired his contractual rights. The court discussed established principles regarding legislative authority, noting that statutes of limitations could be amended by the legislature, provided that a reasonable transition period for filing claims is allowed following any changes to the law.

Analysis of Reasonable Time

The court highlighted that the legislative rationale behind the limitation periods ought to provide plaintiffs with a reasonable timeframe to file their claims. The time between the approval and the effective date of the law was scrutinized, with the court determining that the window provided was adequate for Saladas to defend his rights before the new law became applicable.

Effect of Prior Actions on Prescriptive Period

Saladas also claimed that the time spent engaged in previous court actions interrupted the running of the prescriptive period. However, the court pointed out discrepancies in the legal precedents cited by both parties concerning the interruption of actions under the Civil Code, ultimately ruling that his earlier court filings should indeed extend the time period available to him due to the nature of continuous claims and c

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