REMEDIAL LAW | Billones vs CIR G.R. No. L-17566, July 30, 1995
Billones vs CIR
G.R. No. L-17566, July 30, 1995
FACTS Petitioners were allegedly employees of Luzon Stevedoring Corporation, required to work 18 hours daily without overtime compensation. In June 1954, petitioners, along with crew members, formed the Universal Marine Labor Union and filed a claim for accrued overtime compensation for the period from 1948 to 1954 with the Wage Administration Service (WAS). The claim was dropped after the Union entered into a Collective Bargaining Contract with the company, which was considered a full settlement of their claims. Later, petitioners, claiming they had not authorized the dismissal of their claim, filed new complaints in 1958 for overtime compensation and other benefits for the period from 1948 to 1956. Respondent Luzon Stevedoring moved to dismiss these cases, arguing that the claims were barred by prior judgment, released, and subject to prescription as per Republic Act No. 1993, which imposed a three-year limitation on such claims. Whether Republic Act No. 1993 should be given a retroactive effect and whether the petitioners' claims were barred by prior judgment or prescription.
RULING Yes. The Supreme Court ruled that Republic Act No. 1993, which shortened the period for filing claims for unpaid overtime compensation to three years, has retroactive effect. This means that the law applies to actions commenced after its enactment on June 22, 1957, including those claims that had been filed in 1959 and 1960. The Court emphasized that the legislative intent was to apply the provisions retroactively, as indicated by the language of the law itself. Regarding the petitioners' claims, the Court determined that claims for overtime pay prior to February 26, 1956, had prescribed due to the three-year limitation set by the new law. However, claims for the period from February 26, 1956, to December 31, 1956, were not barred and were remanded for further proceedings to allow for the presentation of evidence.