Onofre v. Montero

Summary

Twenty-one employees of Times Transportation Co., Inc. filed complaints for illegal dismissal, unfair labor practice, and money claims after being dismissed in October-November 1997 for participating in an illegal strike. The employees initially filed complaints in May 1998 but voluntarily withdrew them in March 1999. They refiled new complaints in June-July 2002, nearly five years after their dismissal. The Labor Arbiter granted relief to some employees, but the NLRC, Court of Appeals, and Supreme Court all found the complaints barred by the four-year prescriptive period under Article 1146 of the Civil Code. The Supreme Court emphasized that the voluntary withdrawal of the initial complaint negated any tolling effect, leaving the employees in the same position as if no complaint had been filed. The case demonstrates the strict application of prescription periods in labor disputes and the consequences of voluntary withdrawal of legal actions.