GR L 13419; (May, 1960) (Digest)
G.R. No. L-13419; May 30, 1960
Casiano Saladas, plaintiff-appellant, vs. Franklin Baker Company, defendant-appellee.
FACTS
Plaintiff Casiano Saladas was an employee of defendant Franklin Baker Company from December 7, 1949, to June 2, 1952, when he was dismissed. He filed a claim for overtime services rendered during that period with the Wage Administration Service, which found him entitled to P3,799.52 on August 4, 1953. After a demand letter on October 27, 1954, was ignored, plaintiff filed Civil Case No. Q-1299 in the Court of First Instance of Rizal on November 23, 1954, to recover the sum. This case was dismissed without prejudice on January 9, 1956, due to a denied motion for continuance. On July 18, 1957, plaintiff filed the present action for the same overtime compensation. Defendant, in its amended answer, alleged the cause of action had prescribed. After a preliminary hearing on this defense, the lower court dismissed the case on the ground of the statute of limitations, prompting this appeal.
ISSUE
Whether plaintiff’s claim for overtime services rendered from December 7, 1949, to June 2, 1952, is barred by the statute of limitations.
RULING
No, the claim is not entirely barred. The prescriptive period for the action was originally six years under the ruling in Flores vs. San Pedro, applicable to oral contracts. However, Republic Act No. 1993 , approved on June 22, 1957, amended the Eight-Hour Labor Law by introducing Section 7-A, which shortened the prescriptive period to three years from the accrual of the cause of action, applicable to actions commenced after its effectivity. The Court held that while the new three-year period applied to this case (filed after June 22, 1957), it must afford a reasonable time for filing after the law’s enactment to be constitutional. The period from the law’s approval (June 22, 1957) to its effectivity (same date) did not provide a reasonable time. However, the filing of the first case (Civil Case No. Q-1299 on November 23, 1954) interrupted the prescriptive period under Article 1155 of the Civil Code. This interruption lasted from the filing date until the dismissal order became final, calculated as one year, three months, and fourteen days. Adding this interruption period to the original six-year prescriptive period, plaintiff’s action for overtime services rendered from April 1, 1950, to June 2, 1952, was not barred. The order of dismissal was modified, and the case was remanded for further proceedings.