G.R. No. L-17566 and L-17567, July 30, 1965.
Teotimo Billones, Celso Vallecercer, et al., petitioners, vs. The Court of Industrial Relations, and Luzon Stevedoring Corporation and/or Byron S. Hule as Vice-President and General Manager, respondents. (G.R. No. L-17566)

Salvador Villardo, Eulogio V. Mata, et al., petitioners, vs. The Court of Industrial Relations, and Luzon Stevedoring Corporation and/or Byron S. Hule as Vice-President and General Manager, respondents. (G.R. No. L-17567)

FACTS

Petitioners were allegedly employees of respondent Luzon Stevedoring Corporation. In June 1954, they and other crew members formed the Universal Marine Labor Union. As a Union, they filed a claim for accrued overtime compensation (1948-1954) with the Wage Administration Service (WAS). Before the hearing concluded, the Union officers entered into an amicable settlement with the company via a Collective Bargaining Contract, which they presented to the WAS as a “full, complete and final satisfaction” of their claim, and the claim was dropped. Later, petitioners, through their new Union President, filed complaints for overtime compensation (1948-1956) with the Regional Office of the Department of Labor in 1958. These cases were dismissed with prejudice upon the petitioners’ own motions to dismiss, which stated they had no claim against the company. These dismissal orders became final. Subsequently, on February 26, 1959, and April 11, 1960, petitioners filed new cases for overtime compensation and other benefits (1948-1956) with the Court of Industrial Relations (CIR). Respondent Luzon Stevedoring moved to dismiss on grounds including lack of jurisdiction, bar by prior judgment, and prescription under Section 7-A of Commonwealth Act No. 444, as amended by Republic Act No. 1993 (which sets a three-year prescriptive period). The CIR issued conflicting orders: in G.R. No. L-17566 (Case No. 1328-V), an Associate Judge dismissed the entire case based on prescription, holding R.A. 1993 retroactive; in G.R. No. L-17567 (Case No. 1183-V), the Presiding Judge held that only claims prior to February 19, 1956, were prescribed, allowing claims from that date to December 1956 to proceed. Petitioners challenged these orders, arguing R.A. 1993 cannot be applied retroactively as it impairs contracts and vested rights.

ISSUE

Whether Republic Act No. 1993, which amended the Eight-Hour Labor Law by prescribing a three-year period for filing actions, is a valid exercise of legislative power and should be given retroactive effect to bar the petitioners’ claims.

RULING

Yes, Republic Act No. 1993 is a valid exercise of legislative power and should be given retroactive effect. The law is procedural in nature, and no vested right exists in the continuation of a particular statute of limitations. The proviso in the law exempting “actions already commenced before the effective date of this Act” indicates clear legislative intent for retroactive application. The Court had previously applied Section 7-A retroactively in other cases. The petitioners’ earlier filings with the Department of Labor did not suspend the prescriptive period because those claims were dismissed upon the petitioners’ own instance, leaving them as if no action had been commenced. Applying the law retroactively, and to avoid a due process violation, claimants had a reasonable time (one year from the law’s effectivity on June 22, 1957) to file their claims. The petitioners filed in 1959 and 1960, which was beyond this period. Therefore, in G.R. No. L-17566, the order of dismissal is affirmed. In G.R. No. L-17567, the order is modified: claims for overtime from 1948 to February 25, 1956, are prescribed. The case is remanded for hearing on claims from February 26, 1956, to December 31, 1956, and other possible claims.