Facts:

The case involves A. L. Ammen Transportation Company, Inc. and Consolidated Auto Lines, Inc. as petitioners and Jose Borja as the respondent. The events leading to the case began when Jose Borja was employed by the petitioners as a Supervising Inspector from January 1, 1952, until his dismissal on March 10, 1957. His compensation included a basic salary of P180.00 per month, daily per diems of P3.00, and a monthly bonus of P30.00. Following his dismissal, Borja filed a complaint on April 15, 1958, in the Court of First Instance of Albay (Civil Case No. 1905) seeking compensation for overtime work and damages. The petitioners denied the claim, asserting that Borja had previously filed a similar claim with the Department of Labor, which was dismissed with prejudice. While the civil case was pending, Borja initiated proceedings in the Court of Industrial Relations, essentially reiterating his claim for overtime pay. The petitioners responded by asserting the pendency of the civi...

Facts:

Parties and Employment Background

• A. L. Ammen Transportation Company Inc. and Consolidated Auto Lines, Inc. are the petitioners, while Jose Borja is the respondent.
• Respondent was employed by the petitioners as a Supervising Inspector.
• His compensation included a basic salary of P180.00 per month, a daily per diem of P3.00, and a monthly bonus of P30.00, which was considered an integral part of his salary due to its regular payment for meritorious service.

Nature of the Claim and Disputed Overtime

• Respondent asserted that he rendered overtime work in excess of the standard eight hours per day from January 1, 1952, up to and including March 10, 1957.
• The computation of such overtime was to be based on the petitioner’s inspector notebook and/or its abstract kept by the respondents.
• Specific instructions were given that the count of overtime hours should continue up to 6:00 P.M. even if the last inspection ended prior to that time, as additional investigative work was assigned if completed early.
• An allowance of 30 minutes per day for the lunch break was to be deducted from the total working hours.
• Work rendered during Sundays and holidays, not exceeding eight hours, was not to be considered as compensable overtime because the respondents are public service corporations.

Procedural Timeline and Prior Proceedings

• The period of employment covered the period from January 1, 1952, to March 10, 1957, when respondent was dismissed from service.
• On April 15, 1958, respondent filed an action in the Court of First Instance of Albay (Civil Case No. 1905) to recover compensation for the alleged overtime work and for damages.
• In response, the petitioners denied the claim for overtime pay and raised an affirmative defense, asserting that respondent had earlier 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.
• While the civil case was pending, respondent commenced proceedings in the Court of Industrial Relations, effectively reproducing his claim regarding unpaid overtime wages.

Proceedings in the Court of Industrial Relations

• The Court of Industrial Relations conducted a trial in which both parties reproduced their pleadings from the earlier civil action.
• The petitioners further argued that respondent’s claim had prescribed under Republic Act No. 1994, as amended from Commonwealth Act No. 444, contending that any action to enforce a right under the said statute should be initiated within three years after accrual.
• The petitioners also attempted to challenge the jurisdiction of the Court of Industrial Relations on the basis that the case involved only overtime wages without other reliefs.

The Order of the Court of Industrial Relations

• The Court of Industrial Relations rendered an order dated May 9, 1960, directing respondent to be paid overtime compensation for servicing beyond eight hours a day, calculated from the applicable records.
• The bonus and deductions were incorporated into the wage computation according to the instructions given in the disputed memorandum.
• The court made a conclusive finding that despite an internal memorandum prohibiting work in excess of eight hours, sufficient evidence indicated that respondent was repeatedly instructed by his superiors to perform additional trips and inspections, thereby entitling him to the overtime wage award.

Issue:

Prescription of the Claim

• Whether respondent’s claim for overtime compensation was time-barred with reference to Republic Act No. 1994, which requires actions to be commenced within three years after accrual.
• Whether the “actions already commenced” clause under the law permitted administrative filings as a valid commencement of the claim.

Jurisdiction of the Court of Industrial Relations

• Whether the case, which primarily involved overtime wage claims, fell within the jurisdiction of the Court of Industrial Relations.
• Whether the inclusion of reliefs such as reinstatement alongside overtime wages broadened the scope of the court’s jurisdiction.

Effect of the Company Memorandum on Work Hours

• Whether the memorandum prohibiting work beyond eight hours a day was binding on the respondent for the purpose of overtime claims.
• Whether evidence of verbal instructions to perform additional trips and the issuance of daily inspection reports effectively negated the implications of the memorandum.

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Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)