- Petitioner
- Virgilio Callanta
- Respondent
- Carnation Philippines
- Citation
- G.R. No. 70615
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Fernan, J.
- Decided
- October 28, 1986
Summary
This landmark case established that illegal dismissal actions are governed by the four-year prescription period under Civil Code Article 1146 rather than the three-year period under Labor Code Articles 291-292. The Supreme Court ruled that illegal dismissal constitutes an 'injury to the rights of the plaintiff' rather than a mere 'offense' or 'money claim' under the Labor Code. The Court emphasized that employment is a property right protected by due process, and wrongful interference therewith is actionable. While Callanta's complaint was filed over three years after dismissal, it was within the four-year Civil Code prescription period and therefore valid. The Court ordered three years' backwages but noted reinstatement was impractical due to business takeover.