- Petitioner
- Teekay Shipping Phils.
- Respondent
- Ramier C. Concha
- Citation
- G.R. No. 185463
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Perez, J.
- Decided
- February 22, 2012
Summary
This case involves a seafarer's illegal dismissal claim and the applicable prescription period. Ramier Concha, hired as Able Seaman by Teekay Shipping, suffered an eye injury one day after deployment and was repatriated after less than a month. He filed complaints in 2001 and 2004 for illegal dismissal and disability benefits. The central issue was whether his claims had prescribed under the three-year period claimed by petitioners or the four-year period under Civil Code. The Supreme Court ruled that illegal dismissal actions constitute injury to rights under Article 1146 of the Civil Code, prescribing in four years, not three years under Labor Code. The Court emphasized that employment is a property right protected by due process. Since Concha's first complaint in 2001 interrupted the prescription period, his 2004 complaint was timely filed. The decision establishes important precedent on prescription periods for seafarer employment disputes and reinforces employment as a fundamental property right.