Petitioner
Philippine Long Distance Telephone Company [Pldt]
Respondent
Roberto R. Pingol
Citation
G.R. No. 182622
Court
Supreme Court
Division
Second Division
Ponente
Mendoza, J.
Decided
September 8, 2010

Summary

This case involves the prescriptive period for filing illegal dismissal and money claims. PLDT maintenance technician Roberto Pingol was dismissed January 1, 2000 for unauthorized absences after hospitalization for mental health issues. He filed complaints March 29, 2004, claiming the prescriptive period was tolled by his follow-ups with PLDT from 2001-2003. The Supreme Court ruled that Pingol's own allegation of the dismissal date in his complaint constituted a judicial admission that could not be contradicted. Since the complaint was filed over four years after dismissal, it was time-barred under Civil Code Article 1146. The Court emphasized that alleged follow-ups without written demand or acknowledgment cannot interrupt the prescriptive period under Civil Code Article 1155. The case demonstrates the strict application of prescription rules even in labor disputes despite constitutional social justice policies.

Intellegal Wiki · Key Holding

An illegal-dismissal claim prescribes in four years; a complainant's own allegation of the dismissal date is a binding judicial admission, and mere follow-ups (no written demand or acknowledgment) do not toll prescription.

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By the Intellegal Editorial Board · September 8, 2010

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