- Petitioner
- Texon Manufacturing
- Respondent
- Grace Millena
- Citation
- G.R. No. 141380
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Sandoval-Gutierrez, J.
- Decided
- April 14, 2004
Summary
This case involves prescription issues in labor disputes. Grace and Marilyn Millena, former employees of Texon Manufacturing, filed complaints for money claims and illegal dismissal respectively in 1995. The employer moved to dismiss on prescription grounds. The Supreme Court affirmed lower tribunals' denial of the motion, establishing key precedents: (1) For money claims under Article 291 Labor Code, the 3-year prescription runs from actual violation/termination, not from accrual of entitlement; (2) Illegal dismissal cases fall under Article 1146 Civil Code's 4-year prescription as injury to property rights; (3) Orders denying motions to dismiss are interlocutory and non-appealable. The decision clarifies prescription periods for different types of labor cases and reinforces procedural rules limiting appeals of interlocutory orders.