GR 151407; (February, 2007) (Digest)
G.R. No. 151407 ; February 6, 2007
Intercontinental Broadcasting Corporation, Petitioner, vs. Ireneo Panganiban, Respondent.
FACTS
Ireneo Panganiban was employed by Intercontinental Broadcasting Corporation (IBC) from May 1986 until his resignation in September 1988. On April 12, 1989, he filed a civil case before the Regional Trial Court (RTC) for unpaid commissions. The Court of Appeals later dismissed this case for lack of jurisdiction, ruling it was a labor claim, in a Decision dated October 29, 1991. Panganiban was re-hired as Vice-President for Marketing from July 1992 to April 1993. On July 24, 1996, he filed a labor complaint for illegal dismissal and unpaid commissions. The Labor Arbiter ruled in his favor, but the NLRC dismissed IBC’s appeal for failure to post a bond. The CA initially annulled the Labor Arbiter’s decision, finding the claims for the 1986-1988 period had prescribed and the 1992-1993 claim fell under SEC jurisdiction.
ISSUE
Whether Panganiban’s claim for unpaid commissions from his 1986-1988 employment had already prescribed.
RULING
Yes, the claim had prescribed. The prescriptive period for money claims under Article 291 of the Labor Code is three years from the time the cause of action accrued, which in this case was upon Panganiban’s resignation on September 2, 1988. The filing of the civil case before the RTC on April 12, 1989, did not interrupt the running of the prescriptive period because the RTC was not a competent court or agency with jurisdiction over the labor claim. An action filed before a body lacking jurisdiction does not toll prescription. The CA’s dismissal of that civil case for lack of jurisdiction on October 29, 1991, meant the prescriptive period, which had been running since September 1988, had already lapsed by that date. Consequently, when Panganiban filed his labor complaint on July 24, 1996, the claim was long barred. The Supreme Court rejected the CA’s finding that the claim was interrupted by the RTC filing or by any alleged acknowledgment of debt, as the claim was already time-barred prior to any such acknowledgment. The Court reinstated the CA’s original Decision dismissing the claim for having prescribed.