- Petitioner
- Pepsi Cola Bottling Company of the Philippines
- Respondent
- Job Guanzon
- Citation
- G.R. No. 81162
- Court
- Supreme Court
- Division
- Third Division
- Ponente
- Cortes, J.
- Decided
- April 19, 1989
Summary
This Supreme Court case resolved the prescription issue in Job Guanzon's illegal dismissal complaint against Pepsi Cola. Guanzon, a route salesman terminated in July 1979 for misappropriating money and falsifying invoices, filed his illegal dismissal complaint only in November 1984, after the related criminal case was dismissed. The Labor Arbiter dismissed the complaint as prescribed under the Labor Code's three-year limitation. The NLRC reversed, applying the Civil Code's four-year period and counting from the criminal case dismissal. The Supreme Court reinstated the Labor Arbiter's decision, holding that the cause of action accrued upon termination in 1979, making the 1984 complaint time-barred under both the Labor Code and Civil Code. The Court emphasized that illegal dismissal actions are independent of criminal proceedings and that employees cannot delay filing complaints while awaiting criminal case outcomes. This case establishes important precedent on prescription periods for labor disputes and the independence of administrative and criminal proceedings.