G.R. No. 158084 ; August 29, 2008
J.K. MERCADO & SONS AGRICULTURAL ENTERPRISES, INC., petitioner, vs. HON. PATRICIA A. STO. TOMAS, in her capacity as Secretary of Labor and Employment, et al., respondents.

FACTS

The Regional Tripartite Wages and Productivity Board, Region XI, issued Wage Order No. RTWPB-XI-03 granting a Cost of Living Allowance (COLA). Petitioner J.K. Mercado & Sons filed an application for exemption from this wage order, which was denied by the Board in a final and executory Order dated April 11, 1994. The order directed petitioner to pay its covered workers the prescribed allowance. Despite this final order, petitioner did not comply.
On July 10, 1998, the private respondent workers filed an Urgent Motion for Writ of Execution to enforce the 1994 Wage Order. Petitioner moved to quash the writ, arguing that the workers’ right to claim the COLA had prescribed under Article 291 of the Labor Code, which provides a three-year period to file money claims. Petitioner contended that since no claim was filed within three years from the finality of the 1994 Order, the obligation was extinguished.

ISSUE

Whether the private respondents’ claim for COLA under the Wage Order has prescribed.

RULING

The Supreme Court denied the petition, ruling that the claim had not prescribed. The Court distinguished between the prescriptive period for initiating a money claim and the period for enforcing a final judgment. Article 291 of the Labor Code, which sets a three-year prescriptive period from the time the cause of action accrues, governs the filing of money claims in general.
However, the obligation in this case had already been adjudicated by a final and executory order of the Wage Board dated April 11, 1994. Petitioner did not appeal this order. Consequently, the issue of the workers’ entitlement was settled with finality. The enforcement of this final order is governed by the rules on execution of judgments. Under Section 1, Rule 39 of the Revised Rules of Court, a final judgment may be executed on motion within five years from the date it becomes final and executory.
The workers’ motion for execution in 1998 was filed within this five-year period from the 1994 Order. Therefore, the right to enforce the judgment had not prescribed. The general rule on money claims yields to the specific rule on enforcing final judgments. This interpretation aligns with the principle of statutory construction that a specific provision prevails over a general one and upholds the constitutional mandate for social justice and protection of labor.