G.R. No. 114776 – 381 Phil. 403 – 324 SCRA 414 – Civil Law – Conflict of Laws – Private International Law – Proof of Foreign Law – Applicability of Foreign Laws
Labor Law – Jurisdiction and Reliefs – Money Claims; Prescriptive Period
In 1978, Menandro Laureano was hired as a pilot by Singapore Airlines Limited (SAL). In 1982 however, SAL was hit by recession and so it had to lay off some employees. Laureano was one of them. Laureano asked for reconsideration but it was not granted. Aggrieved, Laureano filed a labor case for illegal dismissal against SAL. But in 1987, he withdrew the labor case and instead filed a civil case for damages due to illegal termination of contract against SAL. Laureano filed the case here in the Philippines. SAL moved for the dismissal of the case on the ground of lack of jurisdiction. The motion was denied. On trial, SAL alleged that the termination of Laureano is valid pursuant to Singaporean law.
The trial court ruled in favor of Laureano. SAL appealed the case raising the issue of lack of jurisdiction, non applicability of Philippine laws, and estoppel, among others. The Court of Appeals reversed the trial court.
ISSUE: Whether or not Singaporean Law is applicable to this case.
HELD: No. The specific Singaporean Law which holds valid the dismissal of Laureano is not proved in court. As such, the trial court cannot make a determination if the termination is indeed valid under Singaporean Law. Philippine courts do not take judicial notice of the laws of Singapore. SAL has the burden of proof. SAL failed to prove such law hence Philippine law shall apply. However, the case must be dismissed on the ground of estoppel. Under our laws, all money claims arising from employer-employee relationships must be filed within three years from the time the cause of action accrued. Laureano’s cause of action accrued in 1982 when he was terminated but he only filed the money claim in 1987 or more than three years from 1982. Hence he is already barred by prescription.
