Title
A. L. Ammen Transportation Co., Inc. vs. Borja
Case
G.R. No. L-17750
Decision Date
Aug 31, 1962
Jose Borja sued for overtime pay after dismissal; Court of Industrial Relations ruled in his favor, affirming jurisdiction, no prescription, and overtime approval despite company memo.
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Case Digest (G.R. No. L-17750)

Facts:

Employment Details:

  • Respondent Jose Borja was employed by petitioners A. L. Ammen Transportation Co., Inc. and Consolidated Auto Lines, Inc. as a Supervising Inspector.
  • His employment period was from January 1, 1952, to March 10, 1957, when he was dismissed.
  • His compensation included a basic salary of P180.00 a month, P3.00 daily per diems, and a monthly bonus of P30.00.

Claims and Proceedings:

  • On April 15, 1958, Borja filed a case in the Court of First Instance of Albay (Civil Case No. 1905) to recover compensation for overtime work rendered during his employment and damages.
  • Petitioners denied the claim, asserting that Borja had previously filed the same claim with the Department of Labor, Regional Office No. IV at Naga City on May 29, 1957, which was dismissed with prejudice on April 30, 1958.
  • While Civil Case No. 1905 was pending, Borja initiated proceedings in the Court of Industrial Relations, reproducing the same claim.
  • Petitioners raised affirmative defenses, including the pendency of Civil Case No. 1905 and the alleged prescription of Borja’s cause of action.

Court of Industrial Relations Decision:

  • The Court of Industrial Relations ordered petitioners to pay Borja for overtime services rendered beyond eight hours a day from January 1, 1952, to March 10, 1957.
  • The court included the P30.00 monthly bonus as part of Borja’s basic salary and deducted 30 minutes daily for lunch breaks.
  • The court ruled that work on Sundays and holidays not exceeding eight hours was not compensable overtime.

Issue:

  1. Prescription of the Cause of Action:

    • Whether Borja’s claim for overtime pay had prescribed under Republic Act No. 1994, which amended Commonwealth Act No. 444, requiring actions to be filed within three years from accrual.
  2. Jurisdiction of the Court of Industrial Relations:

    • Whether the Court of Industrial Relations had jurisdiction over Borja’s claim, given that it primarily sought overtime wages.
  3. Applicability of the Memorandum Prohibiting Overtime:

    • Whether the company’s memorandum prohibiting employees from working beyond eight hours daily applied to Borja, despite evidence that he worked overtime with the company’s knowledge.

Ruling:

The Supreme Court affirmed the decision of the Court of Industrial Relations, ruling in favor of Borja. The court held that:

  1. Prescription:

    • Borja’s action was not barred by prescription because he had filed his claim with the Department of Labor on May 29, 1957, before the effective date of Republic Act No. 1994 (June 22, 1957). The term "actions already commenced" in the statute includes administrative proceedings.
  2. Jurisdiction:

    • The Court of Industrial Relations had jurisdiction because Borja’s complaint included a request for reinstatement, bringing the case within the court’s jurisdiction over labor disputes.
  3. Overtime Work:

    • The company’s memorandum prohibiting overtime did not apply to Borja, as there was evidence that he worked overtime with the company’s knowledge and approval.

Ratio:

  1. Liberal Construction of Labor Laws:

    • Labor statutes must be liberally construed in favor of the laborer (Article 1702, New Civil Code). The term "actions" in Republic Act No. 1994 includes both judicial and administrative proceedings.
  2. Jurisdiction Over Labor Disputes:

    • The Court of Industrial Relations has jurisdiction over cases involving not only monetary claims but also reinstatement, which Borja implicitly sought.
  3. Knowledge and Approval of Overtime:

    • Despite a company memorandum prohibiting overtime, evidence showed that Borja worked overtime with the company’s knowledge and approval, making the memorandum inapplicable to him.


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