Pablo R. Magno v. Philippine National Construction Corp. (Pncc)

Summary

Pablo Magno, a regular PNCC employee, worked overseas in Hong Kong from 1979-1983. Upon returning to Philippines in January 1983, he received no work assignment or salary, allegedly being 'floated' pending new assignment. He filed complaint in December 1987, initially for separation pay, later amended to include illegal dismissal seeking reinstatement. Labor Arbiter ruled in his favor, but NLRC reversed, finding the claim prescribed under Civil Code Article 1146's four-year limitation for injury to rights. Supreme Court affirmed, holding that illegal dismissal constitutes injury to rights subject to four-year prescription, which had expired since cause of action accrued in January 1983. The Court rejected arguments that absence of formal termination prevented prescription from running, emphasizing that laws assist the vigilant, not those who sleep on their rights.