G.R. No. L-18389; January 31, 1963
MANILA RAILROAD COMPANY, petitioner, vs. COURT OF INDUSTRIAL RELATIONS and KAPISANAN NG MGA MANGGAGAWA SA MANILA RAILROAD, respondents.

FACTS

On February 10, 1950, the Court of Industrial Relations (CIR) rendered a decision in Case No. 270-V, ordering petitioner Manila Railroad Company (MRR) to pay a 25% night differential for work performed from 6:00 p.m. to 6:00 a.m. On June 8, 1960, the respondent Union filed a motion to compel payment of this differential for Gate Crossing Keepers for the period February 1 to October 31, 1950. MRR opposed, invoking the Supreme Court’s ruling in National Development Company v. Aralar (G.R. No. L-14258, July 26, 1960), which held that a final CIR award can be enforced by motion only within five years from its entry; otherwise, a new action is required. The CIR, however, directed its Chief Examiner to compute the amount due, resulting in a report for P6,938.63. MRR objected, arguing the claim had prescribed.

ISSUE

Whether the Union’s motion to enforce the 1950 CIR decision, filed more than ten years later, is barred by prescription under the doctrine established in the Aralar case.

RULING

The Supreme Court dismissed MRR’s petition and affirmed the CIR order, holding that the claim had not prescribed. The legal logic is that the five-year period for enforcing a judgment by motion was tolled or interrupted. The Court found that due to MRR’s poor financial condition, the execution of the 1950 award was periodically deferred by agreement of the parties with court approval. A key CIR order dated January 26, 1956, noted the Union had agreed to suspend enforcement of the night differential demand until January 1, 1956. This deferment, granted for MRR’s benefit, constituted a waiver by MRR of its right to insist on execution within the original prescriptive period. Consequently, the five-year period should be computed from January 1, 1956, the expiration of the agreed suspension. The Union’s motion filed on June 8, 1960, was therefore well within the recomputed period. The ruling distinguishes this case from Aralar, where there was no such interruption. The Court applied the general principle that time during which execution is stayed by agreement of the parties or by delay occasioned by the judgment debtor is excluded in computing the prescriptive period. Thus, the motion for an alias writ of execution was timely, and the CIR correctly ordered payment of the differentials to the Gate Crossing Keepers, who were deemed covered by the original 1950 decision as workers similarly situated to the original petitioners.