Accessories Specialist v. Alabanza

ACCESSORIES SPECIALIST, INC. VS. 1.
A promise was reasonably expected to induce action or

forbearance;
ALABANZA 2. Such promise did, in fact, induce such action or forbearance; and
559 SCRA 550 3. Party suffered detriment as a result.
ALL THE REQUISITES OF PROMISSORY ESTOPPEL ARE

FACTS:
PRESENT IN THIS CASE. Jones relied on the promise of ASI that he
Erlinda, in behalf of her husband Jones, filed a complaint against Accessories
would be paid as soon as the claims of all the rank-and-file employees had
Specialists, Inc. (ASI) and Tadahiko Hashimoto for non-payment of salaries,
been paid. If not for this promise that he had held on to until the time of his
separation pay, and 13th month pay.
death, we see no reason why he would delay filing the complaint before the
LA. Thus, we find ample justification not to follow the prescriptive period
Erlinda alleged that:
imposed under Article 291 of the Labor Code. Great injustice will be
 Jones was the VP, Manager and Director of ASI and rendered
committed if we will brush aside the employee’s claims on a mere
outstanding services for the ASI from 1975 to October 1997.
technicality, especially when it was AIS’s own action that prevented
 On October 1997, Jones was compelled by the owner of ASI,
respondent from interposing the claims within the required period.
Tadahiko Hashimoto, to file his involuntary resignation because
ASI suffered losses due to lack of market and incurred several
debts.
 At the time of his resignation, Jones had unpaid salaries for
eighteen (18) months from equivalent to P396,000 and
US$38,880.00, separation pay for P462,000 and US$45,360.00 and
13th month pay for P33,000.
 Jones demanded payment of his money claims upon resignation
but ASI informed him that it would just settle first the money
claims of the rank- and-file employees, and his claims will be paid
thereafter.
 Jones died and failed to receive his claims.
ASI alleged that:

 Erlinda’s cause of action has already prescribed and is forever
barred on the ground that under Article 291 of the Labor Code,
all money claims arising from an employer-employee relationship
shall be filed within 3 years from the time the cause of action
accrues. Since the complaint was filed almost 5 years from the
date of the alleged illegal dismissal of Jones, Erlinda’s complaint
is now barred.
LA: Granted. ASI is ordered pay Erlinda.
On April 22, 2004, the resolution became final and executory. Thus, Erlinda
filed a motion for execution and was duly granted by the LA.
ASI filed a petition praying for the issuance of a TRO and a writ of
preliminary injunction.
CA: Dimissed.
ISSUE:
Whether the cause of action of respondents has already prescribed;
HELD:
NO.
IT WAS ASI WHICH WAS RESPONSIBLE FOR THE DELAY IN THE

INSTITUTION OF THE COMPLAINT. When Jones filed his resignation,
he immediately asked for the payment of his money claims. However, the
management of ASI promised him that he would be paid immediately after the
claims of the rank-and-file employees had been paid. Jones relied on this
representation. Unfortunately, the promise was never fulfilled even until the
time of Jones’ death.
In light of these circumstances, we can APPLY THE PRINCIPLE OF

PROMISSORY ESTOPPEL, which is a recognized exception to the 3-year
prescriptive period enunciated in Article 291 of the Labor Code.
PROMISSORY ESTOPPEL MAY ARISE FROM THE MAKING OF A

PROMISE, EVEN THOUGH WITHOUT CONSIDERATION, IF IT
WAS INTENDED THAT THE PROMISE SHOULD BE RELIED
UPON, AS IN FACT IT WAS RELIED UPON, AND IF A REFUSAL TO
ENFORCE IT WOULD VIRTUALLY SANCTION THE
PERPETRATION OF FRAUD OR WOULD RESULT IN OTHER
INJUSTICE. Promissory estoppel presupposes the existence of a promise on
the part of one against whom estoppel is claimed. The promise must be plain
and unambiguous and sufficiently specific so that the court can understand the
obligation assumed and enforce the promise according to its terms.
In order to make out a claim of promissory estoppel, a party bears the burden
of establishing the following elements: (EID)

Accessories Specialist v. Alabanza

Uploaded by

Copyright:

Available Formats

Accessories Specialist v. Alabanza

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Accessories Specialist v. Alabanza

Uploaded by

Copyright:

Available Formats

ACCESSORIES SPECIALIST, INC. VS. 1.

A promise was reasonably expected to induce action or

ALL THE REQUISITES OF PROMISSORY ESTOPPEL ARE

ASI alleged that:

LA: Granted. ASI is ordered pay Erlinda.

IT WAS ASI WHICH WAS RESPONSIBLE FOR THE DELAY IN THE

In light of these circumstances, we can APPLY THE PRINCIPLE OF

PROMISSORY ESTOPPEL MAY ARISE FROM THE MAKING OF A

You might also like