Saladas v. Franklin Baker Company

Summary

Employee Casiano Saladas sued Franklin Baker Company for P3,799.52 in unpaid overtime compensation for services rendered from 1949-1952. The Court of First Instance dismissed the case as barred by the statute of limitations under Republic Act No. 1993, which shortened the prescription period from six years to three years. The Supreme Court modified the decision, holding that while RA 1993 was constitutional, the Civil Code's provisions on interruption of prescription applied. The filing of a previous case and written extrajudicial demand interrupted the prescription period for one year, three months and fourteen days. The Court allowed recovery for overtime services from April 1, 1950 to June 2, 1952, demonstrating the constitutional limits on retroactive application of shortened prescription periods and the interplay between labor law rights and procedural requirements for their enforcement.